ML20043B499
| ML20043B499 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/23/1990 |
| From: | Chrzanowski R COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20043B500 | List: |
| References | |
| GL-83-37, NUDOCS 9005300110 | |
| Download: ML20043B499 (26) | |
Text
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S n'4 Commonwealth Edison e
Zion Generating Station Shiloh Blvd. & Lake Michigan Zion. Illinois 60099 a
. Telephone 708 / 746-2084 i
- i 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 Units 1 and 2 Application for-Amendment to Facility Operating Licenses DPR-39 and DPR-48 MRC Docket Nos. 50-295 and 50-304
Dear _Dr.-Murley:
Commonwealth Edison proposes to amend Appendix A, Technical Specifications for Facility Operating Licenses DPR-39 and DPR-48 for the Zion Station, pursuant to 10 CFR 50.90.
This proposed Technical Specification change is submitted in accordance with NRC Generic Letter 83-37, regarding the l
incorporation of the Post Accident Monitoring Instrumentation into the Zion Station Technical Specifications.
cAttachment 1 to this letter contains a summary status of the Zion
' Station Generic Letter 83-37 items.
The Technical Specifications required to satisfy the generic letter requirements regarding Control Room Habitibility will be submitted at a later date. contains a brief description l
of the purpose of.the Accident Monitoring System. provides a L
history of-the correspondance between Commonwealth Edison and the NRC l
concerning this matter. contains a summary of the proposed changes. Attachment 5 contains marked-up_ Technical Specification pages and a-copy of the retyped Technical' Specification pages.
L The proposed changes have been reviewed and approved by both onsite-and offsite review in accordance with 10 CFR 50.92 (c).
Commonwealth Edison has determined that no significant hazards consideration exists and has performed an Environmental Assessment.
Documentation of these reviews is contained in Attachments 6 and 7.
900530011o 900523 PDR ADOCK 0500 5
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i provides a cross comparison between the Regulatory Guide 1.97 Rev. 2 Type A variables and the specification where they have been incorporated. Attachment 9 provides a listing of the remaining Category B through E variables referenced in the Technical Specifications.
Finally, 0 contains a summary of the unchanged items that have been _in compliance with the requirements of Generic Letter 83-37.
Commonwealth Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments-to the designated state official.
Please direct any questions regarding this matter to this office.
Very truly yours, 7
G7/st2/
R.Aphrzanowsk NuclearLicynsingAdministrator Attachments:
- 1) Status of Generic Letter 83-37 Items
- 2) Purpose of the Accident Monitoring System
- 3) History of Communications for GL 83-37
- 4) Summary of Proposed Changes
- 5) Marked-up Technical Specification Pages and Typed Technical Specification Pages
- 6) Evaluation of Significant Hazards Consideration
- 7) Environmental Assessment
- 8) Comparision Between RG 1.97 Type A Variables and the Proposed Specification 9)
Listing of the remaining Category B through E variables
- 10) Unchanged Parameters cc:
C. Patel - NRR lion Resident Inspector Region III Office Office of Nuclear Facility Safety - IDNS e
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ATTACHMENT 1
.O STATUS OF GENERIC LETTER 83-37 NUREG 0737 TECHNICAL L
SPECIFICATION ENCLOSURE 1 ITEMS The following information provides a status of all Enclosure 1 Items to Generic Letter 83-37.
(1) Reactor Coolant System Vents (IIB.1)
At least one-reactor coolant system vent path (consisting of at least two valves in series which are powered from emergency busses) shall-be operable and. closed at all times (except for cold shutdown and refueling) at each of the following locations:
- a. Reactor Vessel Head
- b. Pressurizer steam space
- c. Reactor coolant system high point STATUS:
This item has been complied with as addressed in Technical Specification 3/4.3.1.G (2)
Post-accident Samoling (II.B.3)
Licensees should ensure that their plant has the capability to obtain and analyze reactor coolant and containment atmosphere samples under accident conditions. An administrative program should be established, implemented and maintained to ensure this capability.
The program should include:
a) training of personnel b) procedures for sampling and analysis, and c) provisions for maintenance of sampling and analysis equipment.
It is acceptable to the Staff, if the licensee elects to reference this program in the administrative controls section of the Technical Specifications and include a detailed description of the program in the plant operation manuals. A copy of the program should be easily available to the operating staff during accident and transient conditions.-
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STATUS:
The requirement to have Post-Accident Sampling Procedures is currently in Zion Station's Technical Specifications as Specification 6.2.1.L.
This Specificati0n is being revised in this subm.ttal to address the program to include; the requirements of training personnel, procedures for sampling and analysis, and maintenance of sampling and analysis equipment.
(3) long Term Auxiliary Feedwater System Evaluation (II.E.1.1)
The objective of this item is to improve the reliability and performance of the Auxiliary Feedwater (AFH) system.
Technical Specifications depend on the results of the licensee's evaluation and staff review of each plant.
The Limiting Conditions of Operation (LCO) and surveillance requirements for the AFH system should be similar to safety related systems.
STATUS:
This item has been complied with as addressed in Technical Specification 3/4.7.2.
(4) Hoble Gas Effluent Monitori (II.F.1.1)
Noble gas effluent monitors provide information, during and following an accident, which are-considered helpful to the operator in accee-ing the plant condition.
It is desired that these monitors be opeiaole at all times during plant operation, but ihey are not required for safe shutdown of the plant.
In-case of failure of the-monitor, appropriate actions should be taken to restore its operational capability in a reasonable period of time.
Considering the importance of the availability of the equipnent and possible delays involved in administrative controls, 7 days is considered to be the appropriate time period to restore the operability of the monitor. An. alternate method for monitoring the effluent should be initiated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the identification of the failure of the monitor.
If the monitor is not restored to operable conditions within 7 days after the failure a special report should be submitted to the NRC within 14 days following the event, outlining the cause of inoperability, actions taken and the planned schedule for restoring the system to operable-states.
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STATUS:
These monitors are currently contained in Zion-Station Technical Specification Table 3.12-1.
A new action statement is'being proposed
'to incorporate the requirements of Generic Letter 83-37 in this submittal.
1 (5). Samolina and Analysis-of Plant Effluents-(II.F.1.2)
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Each operating nuclear power reactor should have the capability to collect and analyze or measure representative samples of radioactive iodines and particulates in plant gaseous effluents during and following an accident. An administrative program should be established, implemented and maintained to ensure this_ capability.
The program should include:
a) trcining of personnel b) ptocedures for sampling and analysis, and c) provisions for maintenance of sampling and analysis equipment l
It is acceptable to the staff, if the licensee elects to reference this program in the administrative controls section of the Technical Specifications and include a detailed description of the program in the plant operation manuals. A copy of the program should be-readily available to the operating staff during accident and transient _
conditions.
STATUS:
This-item is being proposed for incorporation into Technical Specification 6.2.1.L. as addressed in Generic Letter 83-37 in this submittal.
j (6) Containment High Ranae Radiation Monitor.(II.F.1.3)
A minimum of two in conMnunt tadadon W monMors @ a 7
maximum range of 10g rad /hr (10 R/hr for photon only) should be operable at all times except for cold shutdown and refueling-outages.
In case of failure of the monitor, appropriate actions should be taken to restore its operational capability as soon as-possible.
If the monitor is not restored to operabl9 condition within 7 days after the failure, a special report.siauld be submitted to the NRC within 14 days following the event, outl..itng the cause of inoperability, actions taken and the planned schedule for restoring the equipment to operable status.
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. STATUS:
These monitors are currently contained in Zion Station Technical Specification Table 3.14-1.
A new action statement is being proposed to incorporate the requirements of Generic Letter 83-37 in this submittal.
l (7) Containment Pressure Monitor (II.F.1.4)
Containment pressure should be continuously indicated in the control room of each operating reactor.during Power Operation Start-up and Hot Standby modes of operation.
Two channels should be operable at' all times when the reactor is operating in any of the above mentioned"
- modes, Technical Specifications for these monitors should be
-included with other accident monitoring instrumentation in the present Technical. Specifications.
Limiting conditions for operation (including the required Actions) for the containment pressure monitor should be similar to other accident monitoring instrumentation-included in the present Technical Specifications.
L STATUS 1' This item is being proposed for incorporation into.the Post Accidert
)
Monitoring Instrumentation Table 3.8.9-1.
Reference-to the Narrow Range Containment Pressure instrumentation will be changed to Hide Range to be' consistent with the instrumentation approved in Zion Station's Regulatory Guide 1497 submittal.
This proposed change is being made in accordance with the guidance specified in Generic Letter 83-37.
(8) C_ontainment Water Level Monitor (II.F.1.5),
'A continuous indication of containment water level should be provided in the control-room of each reactor during Power Operation, Start-up and Hot Standby modes of operation. At least one channel for narrow range and two channels for wide range instruments should be operable L
at all times when the reactor is operating in any of the above modes.. Harrow range instruments-should. cover the range from the bottom to the top of the containment sump. Hide range instruments should cover the range from the bottom of the containment to the elevation equivalent to a 600,000 gallon (o-less if justified) l.
. capacity.
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Technical Specifications for' containment water level monitors should be included with other accident monitoring instrumentation in the present Technical Specifications.
LCOs (including the required Actions) for wide range monitors should be similar to other accident monitoring instrumentation included in the present Technical Specifications.
LCOs for narrow range monitor should include the requirement that.the inoperable channel-will be restored to operable status within 30 days or the plant will be brought to Hot Shutdown condition as required for other accident monitoring instrumentation.
STATUS:
1 This. item is being proposed for. incorporation'into Accident Monitoring Instrumentation Table 3.8.9-1 in this submittal.
This change is in accordance with the guidance specified in Generic Letter 83-37.
= (9) Containment Hydrogen Monitor (II.F.1.6)
Two independent containment hydrogen monitors should be operable at all times when the reactor'is operating in Power Operation or Start-up' modes.
LCO for these monitors should include the 9
requirement that with one hydrogen monitor inoperable, the monitor should be restored to operable status within 30 days or the plant should be brought to at least a hot standby condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If both monitors are inoperable, at least one monitor should be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant should be brought to at least hot standby condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
-STATUS:
This item has been complied with as addressed in Technical Specification 3/4.8.8.B.
(10) Instrumentation for Detection of Inadequate Core Cooling (II.F.2)
Subcooling margin monitors, core exit thermocouples, and a reactor 3~
coolant inventory tracking system (e.g., differential pressure 7
measurement system designed by Westinghouse, Heated Junction L
Thermocouple System designed by Combustion Engineering, etc.) may be.
used to provide indication of the approach to, existence of, and l
recovery from inadequate core cooling (ICC).
These instrumentations L
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should be operable during Power Operation, Start-up, and Hot Shutdown modes of operation for each reactor.
Subcooling margin monitors should have already been included in the present Technical L
J Specifications.
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- Technical Specifications for core exit thermocouples and the reactor coolant inventory-tracking system should be includad with other accident monitoring instrumentation in the present Technical Specifications.. Four core exit thermocouples in each core quadrant-and two channels in the reactor coolant tracking system are required to be' operable when the reactor is operating in any of the above mentioned modes. Minimum of two core exit thermocouples in each-quadrant and one channel in the reactor coolant tracking system should be operable at all times when the reactor is operating in any of the above mentioned modes.
STATUS:
These items are being proposed for incorporation into the Post-Accident Monitoring Instrumentation Table 3.8.9-1 in this submittal. These changes are in accordance with the guidance specified in Generic Letter 83-37.
(11) Control Room Habitability Reauirements (1I1.0.3.4) 1 Licensees should assure that control room operators will be adequately protected against the effects of the accidental release of toxic and/or radioactive gases and.that the nuclear power plant can be safely operated or shutdown under design basis accident
' conditions.
If the results of the analyses of postulated accidental release of toxic gases (at or near the plant) indicate any need for installing the toxic gas detection system, it should'be included in the Technical Specifications. All-detection systems'should be included in the Technical Specifications.
In addition to the above requirements, other aspects of the control room habitability requirements should be included in the Technical Specifications for the control room emergency air cleanup system.
Two-independent control room emergency air cleanup systems should be operable n
continuously during all modes of plant operation and capable of meeting design requirements.
STATUS:
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T9chnical Specifications to address these concerns will be submitted at a later date. Several design and licensing issues must be reviewed to assure that the proposed specifications are properly written to address all of the appropriate concerns. ~ Completion of this review is targeted for June 30, 1990. After completion of this review, we will inform you as to our plans to submit a Technical Specification change.
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1 ATTACHMENT 2 PURPOSE Of THE ACCIDENT HONITORING SYSTEM The operability of the accident monitoring instrumentation assures that there is sufficient information available on selected plant parameters to perform manual actions, and to monitor and assess plant status and behavior fc11owing an accident.
Regulatory Guide 1.97 specifies the types, design, and qualification criteria that must be met for these instruments.
These instruments are categorized into several types; Type A, are those that supply information necessary for personnel to perform manual actions during an accident that are essential for direct accomplishment of specified safety functions for which no automatic control is provided.
Type A variables do not include variables associated with contingency actions.
Type B, variables supply information to indicate whether plant safety functions are being.ccomplished. Type C Variables supply information indicating the potential for or the actual breach of fission product barriers.
Type D, variables supply.information to indicate the operation of individual safety related or important to safety systems.
Type E, variables supply information used in determining and continuously assessing the magnitude of radioactive releases. All Type A variables for Zion Station were identified in Zion Stations Regulatory Guide 1.97 revision 2 submittal dated August 1, 1986. As a minimum, these variables are included into the Technical Specifications to assure the availability of information required to perform manual actions following an accident.
These variables are listed in Attachment 8 " Zion Station Type A Variables" of this submittal, identifying which Technical Specification they are incorporated into.
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ATTACHMENT 3 HISTORY Following is a listing of correspondence related to this submittal.
This is included to provide a brief history regarding selected variables referenced in this submittal.
April 20, 1981, Zion Station was issued Amendments 63 and 60 to facility Operating License No,'s DPR-39 and DPR-48.
These amendments incorporated the requirements for implementation of the THI-2 Lessons Learned Category "A" items.
November 1, 1983. Generic Letter 83-37 regarding NUREG 0737 Technical Specifications was issued.
October 28, 1985, NRC Memorandum D.M Crutchfield to T.M. Novak regarding Relief and Safety Valve Position Indicators was issued.
August 1, 1986, Commonwealth Edison transmitted to H.R. Denton a review describing how the requirements of Regulatory Guide 1.97 have or will be met at Zion Station. At that time, Commonwealth Edison identified several instruments that required modifications to meet Regulatory Guide 1.97 design and qualification criteria.
The following instruments related to this submittal were identified:
- Refueling Nam Storage Tank Level.
- RCS Subcooling,
- Condensate Storage Tank Level.
February 2, 1987, Commonwealth Edison re-enforced commitments made to upgrade the Core Exit Thermocouples and RCS Subcooling Monitors to meet Regulatory Guide 1.97 revision 2 qualifications for Unit 2 by &ily 1, 1987, and Unit I during the Fall 1987 refueling outage.
16 addition, commitments were made to address the Refueling Hater Storage Tank 14 vel indicators, and Condensate Storage Tank indicators during the first scheduled refuel outages for Units 1 and 2, nine months followin) HRC approval of Zion Station's Regulatory Guide 1.97 revis!on 2 submittal.
May 15, i987, the NRC issued an interim Technical Evaluation Report regarding Commonwealth Edison's August 1, 1986 Regulatory Guide 1.97 3
submittal.
This report concluded that the exceptions to Regulatory Guide 1.97 Revision 2 items provided by Commonwealth Edison were acceptable, with the exception of 22 items. Commonwealth Edison wM requested to review the interim report and provide a response to these items.
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August 24. 1987, Commonwealth Edison responded to all but 2 of the items from the NRC interim Technical Evaluation Report dated May 15, 1987. At this time, Commonwealth Edison committed to upgrade the Pressurizer Safety Valve Temperature elements to comply with Regulatory Guide 1.97 revision 2 environmental qualification recommendations.
These upgrades were to be scheduled pending final resolution of all Regulatory Guide 1.97 revision 2 issues, and evaluation of environmental qualification requirements.
December 8, 1987, Commonwealth Edison Responded to the two remaining
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exceptions identified in the May 15, 1987 letter referenced above.
April 14, 1989, the NRC transmitted Zion Station's Regulatory Guide 1.97 revision 2 Safety Evaluation Report.
The results of this review concluded that Zion Station was acceptable in respect to conformance with Regulatory Guide 1.97 revision 2 in all areas except for; accumulator level and pressure, neutron flux monitors, and containment isolation valve position indication.
These three issues will be responded to separately from this submittal, l
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ATTACHMENT 4
SUMMARY
OF PROPOSED CHANGES The Technical Specification changes in this letter are being submitted in accordance with the guidance given in NRC Generic Letter 83-37, 3
regarding NUREG 0737 Technical Specifications, and NRC Memorandum, r
D.H. Crutchfield to T.M. Novak regarding Relief and Safety Valve i
Position Indication.
Zion Station's Regulatory Guide 1.97 revision 2 submittal was utilized in the selection of all appropriate instrumentation.
This submittal includes all of the Type A variables identified for Zion Station (Attachment 8).
The instrumentation specified in this submittal currently meet or will be upgraded to meet i
the design and qualification criteria specified in Regulatory Guide 1.97 revision 2.
The following is a brief description of the proposed changes being submitted and their associated justifications.
The alphabetic designators annotated in the left hand margin, des 1Snate the corresponding No Significant Hazards Consideration that the change was evaluated under.
A) The Table of Contents page lit was revised to change the following items:
the appropriate page numbers were added to the bases sections where they were previously omitted, changed the title for Technical Specification 3.8.9 to " Accident Monitoring Instrumentation", to be consistent with the proposed amendment, changed the title for Technical Specification 3.12 to " Gaseous Effluent", to match the title of the Specification.
changed Technical Specification 3.10.4 title from "End Anchorages and Concrete" to "End Anchorage and Concrete", to match the title of the Technical Specification.
A) The Table of Contents page v was revised to change the following items:
correct the page references for items 6.2, 6.4, and 6.5 to accurately depict the appropriate pages, and changed the title of Technical Specification 6,3 to " Action to be Taken in the Event of a Reportable Event in Plant Operation" to match the title of the Specification.
A)
The List of Tables page x was revised to change the following items:
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w The page number for item 4.8.9 1 from 192b to 192c due to an additional page associated with this amendment, and the addition of table 4.8.9-2 titled " Accident Monitoring Instrumentation Numbers".
This table was added to provide a cross reference of the accident parameter to the cotresponding instrument.
l E)
The Mode of Applicability for Specification 3.8.9, Accident Monitoring Instrumentation has been revised to include Mode 7.
Generic Letter 83-37 was written to address the neodes of applicability as defined in the Standardized Technical Specifications. Mode 7 in the Zion Station Technical Specifications is defined as; less than or equal to 5% power with reactivity and temperature stated per the specific test.
This mode is synonymous with Mode 2, incorporating specified tests from the Special Test Exemptions in the Standard Technical Specifications.
This change will require the Accident Monitoring Instruments to be i
operable in Modes 1, 2, 3 and 7.
This change is consistent with the intended Modes for the Post Accident Monitoring Instruments in Generic Letter 83-37.
i A) Action statements a and b associated with Technical Specification 3.8.9 have been changed to reference Mode 4 as the shutdown requirement instead of HOT SHUTDOHN mode with i less than 350 degrees f.
Mode 4iscurrentlyspecifiedinth!yharenthesisfollowing this statement to provide clarification in regards to the appropriate condition.
This change will eliminate the ambiguity that exists in this action, because of the Technical Specifications containing 2 different Hot Shutdown modes, one at greater than 350 degrees f, and the other at greater than 200 degrees f and less than or equal t0 350 degrees f.
MODE 4 appropriately defines the required condition for the plant to be placed into. As such, the required mode for the plant to be placed into has not been changed.
A) Surveillance Requirement 3.8.9 has been renumbered to 4.8.9 to be consistent with the 3.0/4.0 numbering and usage rules.
" INSTRUMENT CHANNEL CHECK AND CHANNEL CALIBRATION" have been revised to " CHANNEL CHECK and Instrument CHANNEL CALIBRATION", to be in conformance with the wording specified in the definitions section items 1.7, and 1.8.
These changes are correcting inconsistencies in terminology.
The intent of these items has remained the same.
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The asterisk associated with action statement a, and the asterisk note on the bottom of page 184 has been deleted, replacing these items with an asterisked note on the bottom of Table 3.8.9-1 and asterisks added to the PZR PORV and PORV Block Valve indicators.
These changes are addressed in detail, with the changes associated with the PZR PORV and PORV Block Valve indicators l
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A) The title associated with tables 3.8.9-1 and 4.8.9-1 have been i
relocated to the bottom of the page.
This change was made to place i
the titles where they would be readily seen when in use.
i B) Containment Pressure (Hide Range), Tables 3.8.9-1 and 4.8.9-1 item I has been revised, changing reference from narrow range to wide range.
In addition, the total number of instrument channels in Table 3.8.9-1 l
has been changed from 4 to 2.
These instruments are Type A variables, as identified in Zion Station's Regulatory Guide 1.97 revision 2 submittal. As such, the instrumentation specified in this table must t
meet Category 1 design and qualification criteria to assure availability of the parameter under accident conditions.
Zion Station j
has a total of 2 containment pressure instruments that meet this criteria.
Reference to the Containment Narrow Range Pressure instruments was deleted since these instruments do not meet the design and qualification criteria specified in Regulatory Guide 1.97.
The action statements associated with these changes have remained unchanged.
With less than the required number 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), operations may continue for a l
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 e
these time frames, the unit will 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 />.
The surveillances specified for these instruments in Table 4.8.9-1 have remained unchanged.
The survelliances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly t
channel checks.
These changes have been made to reference the appropriate instruments specified in Zion Station Regulatory Guide 1.97 submittal.
D) Steam Generator Water Level (Hide Range) Table 3.8.9-1 item 8 has been revised. changing the required number of channels from a total of 2 to 1 per Steam Generator, and changing the minimum operable channels from 1 to Not Applicable.
Zion Station has a total of 1 Hide Range Steam i
Generator Water Level Instrument per Steam Generator.
One channel per l-steam generator was justified in Zion Station's Regulatory Guide 1.97 submittal based on, " additional instrumentation which indicates the effectiveness and adequacy of the secondary heat sink".
The additional instrumentation listed were; the Steam Generator Narrow Range Level, with backup from the Reactor Coolant System Temperature and Reactor Coolant Pump Flow.
The Steam Generator Narrow Range Level Instruments cover over 25% of the Steam Generators Hide Range Level Instruments range.
By changing the required number to 1 per Steam Generator, a total of 4 channels will now be required instead of a total of 2.
Based on the currently Technical Specification's, operations could continue for a period of 7 days based on 3 Steam Generator Wide Range Level Instruments falling, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in the event of All 4 instruments failing.
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The proposed changes will allow operations to continued for a period of 7 days based on a single instrument failure on any Steam Generator.
If, the required number of channels are not restored within this time frame the Unit will 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 />.
By specifying Not Applicable as the minimum operable number, action statement b of Specification 3.8.9 requiring restoration in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is not applicable to this item.
Seven days is considered to be an acceptable period of time for a single instrument failing.
The surveillances specified for these instruments in Table 4.8.9-1 have remained unchanged.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
Based on the above information it can be concluded that the overall changes being proposed for the Steam Generator Hide Range Level Instruments are more conservative than the current Specifications, and that the change is justifiable based on the availability of diverse instrumentation (Steam Generator Narrow Range Level Instruments) that provides the same information, thus assuring that a complete loss of indication for the parameter being monitored will not occur.
D) Auxiliary feedwater Flow Rate Table 3.8.9-1 item 10 has been revised, changing the required number of channels from a total of 2 to 1 per Steam Generator, and the minimum operable channels from 1 to Not Applicable.
Zion Station has a total of 1 Auxiliary Feedwater Flow Rate instrument per steam generator, and 3 Auxiliary Feedwater Pump Systems.
Each of the 3 pump systems are capable of providing flow to all 4 steam generators.
The instrumentation provided indicates the combined flow rate to each Steam Generator from all 3 Auxiliary feedwater Pump Systems. The 4 auxiliary feedwater flow rate instruments are powered from redundant instrument busses, 2 from instrument bus 111/211 and the remaining 2 from instrument bus 112/212.
Backup indication is available from the steam generator narrow range instruments, which is a direct indication of heat sink status.
These instruments are Type A Category 1 variables. One channel per steam generator was reviewed and accepted in Zion Station's Regulatory ride 1.97 submittal based on the above information.
By changing the required number to 1 per Steam Generator, a total of 4 channels will now be required instead of a total of 2.
Based on the current Technical Specification's, operations could continue for a period of 7 days based on 3 Auxiliary feedwater flow Rate Instruments failing, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in the event of All 4 instruments failing.
The proposed changes will allow operations to continued for a period of 7 days based on a single instrument failure on any Steam Generator.
If, the required number of channels are not restored within this time frame the unit will 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 />.
By specifying Not Applicable as the minimum operable number, action statement b of Specification 3.8.9 requiring restoration in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is not applicable to this item.
Seven days is considered to be an acceptable period of time for a single instrument failing.
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The surveillances specified for these instruments in Table 4.8.9-1 have remained unchanged. The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
Based on the above information it can be concluded that the overall changes being proposed for the Auxiliary feedwater Flow Rate Instruments are more conservative than the current Specifications, and i
that the change is justifiable based on the availability of diverse
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instrumentation (Steam Generator Narrow Range Instruments) that provides the same information, thus assuring that a complete loss of 1
Indication for the parameter being monitored will not occur.
B)
Reactor Coolant System Subcooling Margin Table 3.8.9-1 item 11 has l
been revised, deleting reference made to procedural calculations.
Procedural calculations were an interim measure used untti additional instrumentation was made available or upgraded.
The reactor coolant i
system subcooling monitor consists of two independent monitoring systems.
With less than the required number of channels operable (2),
but not less than the minimum operable number (1), operations may r
continue for a period of time not to exceed 7 days.
With less than the minimum operable channels (1), 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 these time frames the unit will 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 />.
The surveillances specified for these instruments in Table 4.8.9-1 have remained unchanged.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These instruments are Type A Category i variables.
In Zion Station's Regulatory Guide 1.97 submittal, a commitment was made to either environmentally qualify or replace unqualified components associated with these instruments with safety related components.
These modifications have been completed. As such, the Reactor Coolant System Subcooling Margin Instruments being referred to by this change now meet Category I design and qualification criteria.
This change is being made to place this item into conformance with the guidance given in Generic Letter 83-37.
PZR PORV Position Indicator Table 3.8.9-1 item 12 has been revised, changing the total and required number of channels from_2 to 1, and deleting reference to the double asterisk statement specifying the primary and backup PORV position indicators.
In addition, an asterisked note has been added to the bottom of Table 3.8.9-1, and asterisks added to the PZR PORV, it's required number of channels, and minimum operable channels.
These items have been added to take the place of the asterisk note deleted from the bottom of page 184.
The proposed changes regarding the total and required number of channels, and deletion of the double asterisk statement are summarized as follows:
l l
L l
D)
The Zion Station Technical Specification currently require 2 position indicators per PORV.
These indicators are designated l
as; I stem mounted limit switch, and 1 acoustic monitor.
The stem mounted limit switches for the FORVs have been upgraded, and are now safety related Type D Category 2 meeting all of the requirements for Category 2 instrumentation specified in Regulatory Guide 1.97.
One PORV position Indicator per valve was reviewed and accepted in Zion Station's Regulatory Guide 1.97 submittal.
This change is based on NRC Letter dated October 28, 1985. D.M. Crutchfield to T.M Novak regarding pressurizer relief and safety valve position indicators.
This letter concluded that the only bases for a Technical Specification on backup indication of safety or relief valve position is when a non-safety grade channel is provided as the primary indication of valve position.
The existence of backup indication by itself is not a sufficient basis to impose a Technical Specification requirement when the primary means of valve position indication is safety grade. The proposed change allows for the deletion of the acoustical monitoring backup indicators from the Technical Specifications.
Based on the current Technical Specifications, operations could continue for a period of 7 days based on the inoperability of either a stem mounted limit switch, or an acoustical monitor.
If both of these indicators were inoperable, operations could 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 required number of channels or minimum operable channels are not restored within these time frames the unit vill 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 />.
The proposed changes will allow operations to continued 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 /> based on the inoperability of the stem mounted limit switch alone.
If, the required number of channels (same as the minimum operable number) are not restored within this time frame the unit will 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 />. As such, if the acoustic monitor is assumed to be inoperable the actions required have remained the same.
The surveillances specified for t
these instruments in Table 4.8.9-1 have remained unchanged.
The proposed change still requires periodic surveillances to be performed on the stem mounted limit switches.
The surveillances specified in Table 4.8.9-1 are appropriate for this instrument to assure operability through the performance of 18 month channel calibrations (indicator testing) and monthly channel checks.
The proposed changes.regarding the addition of an asterisked note A) to the bottom of Table 3.8.9-1, and asterisks added to the PZR PORV, its required number of channels and minimum operable channels, are summarized as follows:
The note being deleted on the bottom of page 184 provided an exemption to the shutdown requirements associated with an inoperable PZR PORV or PORV Block Valve position indicator.
This exemption was contingent on the position of the associated PORV Block Valve being known to be closed or verified closed within 7 days.
u
i' e
l Action statements a and b associated with specification 3.3.1.F requires the PORV Block Valve associated with either an inoperable PORV or PORV Block Valve to be closed and de-energized anytime either of these valves is found inoperable in modes 1 2,
or 3.
These actions must be taken within one hour, or an unit shutdown is required.
The position indication for the PORV Block Valve is powered from the same source required to be de-energized in action statements a and b of Specification 3.3.1.F.
This removes power from the PORV Block Valve and PORV Block Valve indicator making both the valve and indicator inoperable.
Specification 3.8.9 currently allows indefinite operation without i
PORV position indication or PORV Block Valve position indication, when the position of the associated PORV Block Valve is known to be closed or verified closed within 7 days.
Specification 3.3.1.F actions a and b require the PORV Block Valve to be closed and de-energized within I hour. The proposed change deletes the requirement to maintain the PORV OR PORV Block Valve associated with an isolated flowpath operable, when the flowpath has been 1solated in accordance with Specificat'on 3.3.1.F.
As such, these changes result in no net change W the existing requirements.
PZR PORV Block' Valve Position Indicator Table 3.8.9-1 item 13 has been revised, changing the minimum operable channels from 0 to 1.
In addition, an asterisked note has been added to the bottom of Table 3.B.9-1, and to the PZR PORV Block Valve Indicator, its required number of channels, and minimum operable channels.
These items have been added to take the place of the asterisk note deleted from the bottom of page 184 as addressed above for the POPV Position Indicators.
The proposed change regarding the minimum operable channels is i
summarized as follows:
D)
Zion Station has a total of 1 valve limit switch position indicator per PORV Blocn Valve.
The PORV Block Valve Position Indicators are Safety Related Type D Category 2 variables. One position indicator per PORV Block Valve'was reviewed and accepted in Zion Station's Regulatory Guide 1.97 submittal.
In accordance with the guidance given in NRC Letter dated October 28, 1985, D.M. Crutchfield to T.H Novak regarding pressurizer relief and safety valve position indicators, backup indication of safety or relief valve position is only required if a non-safety grade channel is provided as the primary indication of valve position.
This logic has been applied to the PORV Block Valves as well.
As such, the required number of channels has remained unchanged.
The minimum operable channels has been revised to 1 per valve, to
~,
be consistent with the guidance given in Generic Letter 83-37.
Based on the current Technical Specifications, operations could
+
continue for a period of 7 days based on the inoperability of the PORV Block Valve Position Indicator, l
1
)
[
If, the required number of channels is not restored within this time frame the unit will be placed in Mode 4 within the next 12 j
hours.
The proposed changes will allow operations to continued 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 /> based on the inoperability of the PORV Block Valve Position Indicator.
If, the required number of channels (the same as the minimum operable channels) are not restored within this time frame the unit will 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 />.
The surveillances specified for this parameter in Table 4.8.9-! have remained unchanged.
The proposed change will still require periodic surveillances to be performed on the PORV Block Valve Position Indicators.
The surveillances specified in Table 4.8.9-1 are appropriate for this instrument to assure operability through the performance of 18 month channel calibrations (indicator testing) and monthly-channel checks.
l A)
The proposed changes regarding the addition of an asterisked note to the bottom of Table 3.8.9-1, and asterisks added to the PZR PORV Block Valve Position Indicator, required number of channels and minimum operable channels are summarized as follows:
The note being deleted on the bottom of page 184 provided an exemption to the shutdown requirements associated with an inoperable PZR PORV or PORV Block Valve position indicator.
This exemption is contingent on the position of the associated PORV Block Valve being known to be closed or verified closed within 7 days.
Action statements a and b associated with specification 3.3.1.F requires the PORV Block Valve associated with either an inoperable PORV or PORV Block Valve to be closed and de-energized anytime either of these valves is found-inoperable in modes 1, 2, or 3.
These actions must be taken within one hour, or a unit shutdown is required.
The position indication for the PORV Block Valve is powered from the same source required to be de-energized in action statements a and b of Specification 3.3.1.F.
This removes power from the PORV Block Valve and PORV Block Valve indicator making both the valve and indicator inoperable.
Specification 3.8.9 currently allows indefinite operation without PORV position indication or PORV Block Valve position indication a
when the position of the associated PORV Block Valve is known to be closed or verified closed within 7 days.
Specification 3.3.1.F actions a and b require the PORV Block Valve to be closed and de-energized within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The proposed change deletes the requirement to maintain the PORV or PORV Block Valve associated with an isolated flowpath operable, when the flowpath has been isolated in accordance with Specification 3.3.1.F.
As such, these changes result in no change to the existing requirements.
A) An asterisk note has been added to the bottom of Table 4.8.9-1 and asterisks have been added to PZR PORV and PORV Block valve Position Indicators.
These changes are being proposed in conjunction with the above changes proposed on the PORV and PORV Block Valve Indicators.
e
a t
The PORV and PORV Block Valve Position Indicators are not required to be operable, when their associated flowpath is isolated as previously addressed.
These changes will exempt the requirement to perform periodic surveillances on these indicators when the PORV Block Valve i
is closed and de-energized in accordance with Specification 3.3.1.F.
The exemption from performing performing periodic surveillance on the PORV and PORV Block Valves currently exists under Specificatto?
4.0.3. ' Specification 4.0.3 does not require surveillances to be performed on inoperable equipment. As such, this change results in no change to the existing requirements.
B) PZR Safety Valve Position Indicator (Primary Detector) Tables 3.8.9-1 and 4.8.9-1 item 14 have been revised, referencing this item as the PZR Safety Valve Position Indicator, primary indicator.
In addition, the required number of channels has been changed from a total of 2 to 1 per valve, the minimum operable channels from a total of 1 to 1 per valve, and reference to a double asterisk note stating the origin of this item has been added.
These change are being proposed in conjunction with proposed item number 15 on Tables 3.8.9-1 and 4.8.9-1, requiring the operability of a backup indicator.
Zion i
Station has 1 thermocouple located in the discharge line of each Safety Valve.
These monitors provide an indication of safety valve position in the control room.
Temperature was selected as the primary detector because, through the use of temperature indication it is possible to detect both large and small flows past the valve.
These instruments are non-safety related Type D Category 3 variables. A commitment-was made to upgrade these instrutnents to Category 2 qualifications in the supplemental report to Zion Station's Regulatory Guide 1.97 submittal dated August 24, 1987.
The use of these detectors as a means of determining Pressurizer Safety Valve position t
was reviewed and approved in Zion Station's Regulatory Guide 1.97 submittal.
The date for modification of these instruments to Category 2 criteria has not been determined yet.
These dates will be submitted in Zion Station's Regulatory Guide 1.97 compliance response.
Zion Station's Regulatory Guide 1.97 compliance response will be submitted by June 30, 1990.
Based on the current Technical Specification's, operations could continue for a period of 7 days based on 2 PZR Safety Valve' Position Indicators failing, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in the event of All 3 instruments failing.
The proposed changes will allow operations to continued for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> based on a lingle failure of a PZR Safety Valve Position Indicator.
If the required number of channels (same as the minimum operable channels) are not restored within this time frame the unit will be placed in Mode 4 within the next 12 l
hours.
The surveillances specified for these instruments in Table 4.8.9-1 have remained unchanged.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
The double asterisk statement added to the PZR Safety Valve Position Indicator and to the bottom of this table provide reference to the origin of this requirement being NUREG 0578 item 2.1.3.a.
I l
i
l i
i These changes are being proposed in accordance with the guidance given in NRC Memorandum, D.M. Crutchfield to T.M. Novak regarding Accident Monitoring Instrumentation Technical Specifications, dated October 28, 1985. This letter concluded that a Technical Specification specifying both primary and backup indication of safety or relief valve position is required when a non-safety grade channel is provided as the primary indication of valve position. As such, both primary and backup indicators are being proposed.
B) PZR Safety Valve Position Indicator (Backup Detector) has been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as i
item 15, specifying a total of 3 (1/ valve) channels, 1/ valve as the required number, and Not applicable as the minimum operable number.
This change is being proposed in conjunction with item 14 above.
Zion Station has 1 acoustic monitor per Safety Valve.
These monitors provide indication of safety valve position in the control room.
l These instruments are type D Category 3 variables.
The use of these instruments as a backup means of determining Pressurizer Safety Valve position was reviewed and approved in Zion Station's Regulatory Guide 1.97 submittal.
With less than the required number of channels operable (1/ valve), operations may continue for a period of time not to exceed 7 days.
If, the required number of channels are not restored within this time frame the unit will 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 />.
By specifying Not Applicable as the minimum operable number, action statement b of Specification 3.8.9 requiring restoration in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> is not applicable to this item.
This item has been added to Table 4.8,9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
This change is being proposed in accordance with the guidance given in NRC Memorandum D.M.
Crutchfield to T.M. Novak regarding Accident Monitoring Instrumentation Technical Specifications dated October 28, 1985.
This letter concluded that a Technical Specification on backup indication of safety or relief valve position is required when a non-safety grade channel is provided as the primary indication of valve position.
B) Core Exit Thermocouples have been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as item 16.
There are a total of 65 thermocouples, with 4 per quadrant specified for the required number and 2 per quadrant for the minimum number in Table 3.8.9-1.
With less than the required number of channels operable (4/ quadrant), but not less than the minimum operable number (2/ quadrant), operations may continue for a period of time not to exceed 7 days. With less than the minimum operable channels (2/ quadrant), 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 />.
I l
p If, the CinituJ operable channels or the required number of channels are not restored within these time frames the unit will 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 />.
This item has been added to Table i
4.8.9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These instruments are Type A Category i variables.
The modifications to environmentally qualify and replace safety related components, stated in Zion Station's Regulatory Guide 1.97 submittal have been completed. As such, the Core Exit Thermocouples referred to in this submittal now meet Category I design and qualification criteria.
These changes are being made consistent with the guidance specified in Generic Letter 83-37.
B) Containment Water Level (Narrow Range) has been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as item 17.
t There are a total of 2 Harrow Range Containment Hater Level Instruments, with 1 specified for the required number and 1 for the minimum number.
The required and minimum operable number of channels have a pound sign notation associated with their action that provides for an allowable outage time of 30 days.
This note has been added to the bottom of page 192b. As such, with less than the required number of channels operable or the minimum operable number, operations may continue for a period of time not to exceed 30 days.
If, the minimum operable channels (same as the required number of channels) are not restored within this time frame the unit will 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 />.
This item has been added to Table 4.8.9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These changes are being made. consistent.with the 5
guidance specified in Generic Letter 83-37.
B) Containment Hater Level (Hide Range) has been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as item 18.
There are a total of 2 Hide Range Containment Water level Instruments, with 2 specified for the required number, and I for the minimum operable number. With less than the required number 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), 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 these time frames the unit will 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 />.
This item has been added to Table 4.8.9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These changes are being made consistent with the guidance specified in Generic Letter 83-37.
i 1
L 1
o i
B) The Reactor Coolant Inventory Tracking System has been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as item 19 and 20.
The Reactor Coolant Inventory Tracking System has been divided into 2 separate line items.
The reason for this change is to address the two different operating modes for this system.
The Reactor Coolant Inventory Tracking System at Zion Station works on a j
differential pressure principle.
This system consists of 4 channels, i
two of which are calibrated for Reactor Coolant Pumps in operation and j
the other two for pumps off.
4 i
Reactor Vessel Water Level (Hide Range at least one RCP running)
]
Table 3.8.9-1 item 19 has a total of 2 instruments, with 2 i
specified for the required number, and 1 for the minimum number.
1 Hith less than the required number of channels operable (2), but not less than the minimum operable number (1), operations may J
continue for a period of time not to exceed 7 days. With less J
than the minimum operable channels (1), 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 these time frames the unit will 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 />.
This item has been added to Table 4.8.9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These changes are being made consistent with the guidance specified in Generic Letter 83-37.
Reactor Vessel Water Level (Narrow Range, all RCPs no.t running)
Table 3.8.9-1 item 20 has a total of 2 instruments, with 2 specified for the required number, and 1 for the minimum number.
With less than the required number 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), operations may continue I
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 channelt are not restored within these time frames the unit will 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 />.
This item has been added to Table 4.8.9-1 to assure operability of this parameter through the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These changes are being made consistent with the guidance specified in Generic Letter 83-37.
l
r l
B) Condensate Storage Tank Level has been added to Accident Monitoring Instrumentation Tables 3.8.9-1 and 4.8.9-1 as item 21.
There are a total of 2 Condensate Storage Tank Level indicators, with 2 specified as the required number, and I for the minimum operable number.
These instruments are Type A Category 1 variables.
Neither of the 2 i
Condensate Storage Tank Level instruments currently meet the design or qualification criteria of Regulatory Guide 1.97.
The modifications to upgrade these instruments will be completed for Unit 1 and 2 during their cycle 13 Refueling Outages. After completion of these modifications, the Condensate Storage Tank Level Indicators will meet Category 1 design and qualification criteria.
With less than the required number 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.
Hith less than the 'ninimum operable j
channels (1), operations may continue for a period of time not to i
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 these time frames the unit will 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 />.
This item has been j
added to Table 4.8.9-1 to assure operability of this parameter through j
the performance of periodic surveillance tests.
The surveillances specified in Table 4.8.9-1 are appropriate for these instruments to assure operability through the performance of 18 month channel calibrations and monthly channel checks.
These changes are being made consistent with the guidance specified in Generic Letter 83-37.
A) M: Monthly, and R: Refueling have been deleted from the bottom of page 192b.
This item is not necessary since the frequencies associated with these two items are appropriately defined in the Definitions i
Section of the Technical Specifications, Table 1.2.
A)
Table 4.8.9-2 " Accident Monitoring Instrument Numbers" has been developed to provide a cross reference between the accident parameter and the instrument used.
These instruments are consistent with those submitted in Zion Station's Regulatory Guide 1.97 submittal.
This table is intended to be a reference aid for personnel.
No actions or requirements are imposed or altered as a result of this table.
A)
Bases Page 195 was revised, to change the following items:
page format to be consistent with that used for other bases pages after revision, added reference to NRC Generic Letter 83-37 into the bases for the accident monitoring instruments, and placing the revision number and date into the Bases to include which revision of Regulatory Guide 1.97 Zion Station's submittal was approved to.
p a
O C) Action Statement 4 has been added to Table 3.12-1.
In addition, the actions associated with the Steam Generator Atmospheric Relief and Safety Valve Radiation Monitors, and the Vent Stack Noble Gas Effluent Radiation Monitors channels 7, and 9 have been revised to reference action 4.
Action Statement 4 was chosen because it is not currently user! in the Technical Specification.
This action statement has been modeled after action 30 of Generic Letter 83-37. Only the actions associated with the Steam Generator Atmospheric Relief and Safety Valves, and the Vent Stack Noble Gas Effluent Radiation Monitors channels 7, and 9 have been revised to reference action 4.
These are the only effluent path radiation monitors that must be considered l
i accident monitors for the following reasons:
The Vent Stack Noble Gas Monitor Channels 7 and 9 are located on the Unit I and 2 Ventilation Stacks downstream of all inputs into the stacks.
The Ventilation Stacks are a common release point for all identified release pathways for gaseous radioactive materials with the exception of the Steam Generator Atmospheric Relief and Safety Valve discharges paths.
Steam Generator Atmospheric Relief and Safety Valve discharges paths are the only exception to the above statement.
As such this pathway has also been included for the purpose of accident monitoring. This position was reviewed and accepted in Zion Station's Regulatory Guide 1.97 submittal.
The Vent Stack Noble Gas Monitor Channels 7, and 9 and the Steam Generator Atmospheric Relief and Safety Valves Radiation Monitors have been changed to reference action 4.
Based on the currently Technical Specification's with these monitors inoperable, the inoperable monitor must be restored to operable status within 30 days, or an alternate means of monitoring the parameter must be established.
The proposed changes will require an alternate method of monitoring the appropriate parameter to be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and to restore the inoperable monitor to operable status within 7 days of the event, or to prepare and submit a report to the commission within 14 days following the event outlining the actions taken, the cause of inoperability, and the plans and schedule for restoring the monitor to operable status.
The surveillances specified for these instruments in Table 4.12-2 have remained unchanged.
These surveillances are appropriate for these instruments to assure operability.
These changes are consistent with the requirements of Generic Letter 83-37.
A) Item number 7.C 4, on page 236b has been changed from "lR-AR34B" to "2R-AR04B".
This change has been made to correct a typographical error.
This monitor should have been referenced as a Unit 2 Monitor.
c L
C) Action Statement 31 has been added to Table 3.14-1.
In addition, the actions associatstd with the Containment Area High Range Monitors have been revised ts reference action 31. Action Statement 31 was chosen because it is not currently used in the Technical Specification.
This action statement has been modeled after action 30 of Generic Letter 83-37.
Based on the current Technical Specifications, with these monitors inoperable, an alternate method of monitoring the appropriate parameter (if feasible) must be initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the inoperable monitor must be restored to operable status within 7 days e
of the event, or a Station Review will be conducted within 14 days to determine a plan of action to restore the monitor to operable status.
The proposed changes will require an alternate method of monitoring the appropriate parameter to be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and to restore the inoperable monitor to operable status within 7 days of the event,ortoprepareandsubmitareporttothecommissionwithin14 days following t event outlining the actions taken, the cause of f
inoperability, and the plans and schedule for restoring the monitor to operable status.
The surveillances specified for these instruments in Table 4.14-1 have remained unchanged.
These surveillances are appropriate for these instruments to assure operability.
These changes are consistent with the requirements of Generic Letter 83-37.
t C) Section 6.2.L. has been revised to include the requireinent to have Post Accident sampling programs capable of obtaining and analyzing reactor coolant and containment atmosphere, and collect and analyze or measure radioactive iodines and particulates in plant gaseous effluents samples under accident conditions.
This program includes; i
the training of personnel, procedures for sampling and analysis, and provisions for maintenance of sampling and analysis equipment.
These changes are consistent with the guidance given in Generic Letter 83-37. As a result of adding this item, Specification 6.2.2 has been moved to page 310, and page 310 has been include as a rtvised page.
A) Item r has been added to Special Report Table 6.6-1 to address the 14 day written report that must be submitted any time a Post Accident Radiation Monitor has b9en inoperable in excess of 7 days.
Addition of th h item reflects the addition of this reporting requirement to the Technical Specifications.
Boric Acid Tank Solution Level item number 10 of Generte Letter 83-37 was not incorporated into this submittal.
The Boric Acid Tank Solution level is not a Type A variable at Zion Station.
Regulatory Guide 1.97 does not contain the Boric Acid Tank Level under any variable type.
The safety function of the Boric Acid Storage Tanks is to maintain sufficient boric acid quantity, to borate the Reactor Coolant System to cold shutdown concentration anytime during the core cycle consistent with the Technical Specifications shutdown margin requirements.
There are no automatic or manual actions required for Design Basis Accident mitigation associated with the Boric Acid Storage Tank.