ML20064C925

Proposed TS 3.3.3.6 Tables 3.3-10 & 4.3-7 Re Accident Monitoring Instrumentation

ML20064C925
Person / Time
Site:	Mcguire, McGuire
Issue date:	02/25/1994
From:	DUKE POWER CO.
To:
Shared Package
ML20064C919	List: ML20064C917 ML20064C925
References
NUDOCS 9403100336
Download: ML20064C925 (12)

Text

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ATTACHHENT 1 PROPOSED CHANGES l

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'l f l INSTRUMENTATION 7

ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION i l

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3.3.3.6 The accident monitoring instrumentation channels shown in Table

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3.3-10 shall be OPERABLE. i APPLICABILITY: MODES 1, 2, and 3.  !

ACTION:

a. With the number of OPERABLE accident monitoring instrumentation channels less than the Required Number of Channels shown in Table 3.3-10, restore the inoperable channel (s) to OPERABLE stttus within 7 days, or de in at least HOT SHUTOOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-10, restore the inoperable channel (s) to OPERABLE status

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c. The provisions of Specification 3.0.4 are not applicable. ,

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SURVEILLANCE REQUIREMENTS

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4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL  :

CALIBRATION operations at the frequencies shown in Table 4.3-7. )

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McGUIRE - UNITS 1 and 2 3/4 3-55

TABLE 3.3-10 d, ACCIDENT MONITORING INSTRUMENTATION c

C -

MINIMUM E

REQUIRED

"' NO. OF CHANNELS

' CHANNELS OPERABLE INSTRUMENT C

5 1. Containment Pressure 2 l' d 2. Reactor Coolant Temperature - T g and T de Range) 2/T H0T 2/T COLD 1/T H0T 1T COLD COLD s 3. ReactorCoolantPressure-WideOInge 2 1 2 1 o, 4. Pressurizer Water Level 2/ steam generator 1/ steam generator E 5. Steam Line Pressure 1/ steam generator 2/ steam generator i

m 6. Steam Generator Water Level ' Narrow Range Refueling Water Storage Tank Water Level 2 1 7.

1/ steam generator

8. Auxiliary feedater Flow Rate 2/ steam generator Reactor Coolant System Subcooling Margin Monitor 2 1 4

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Safety Vah: . Citi;; hditat r 2!::hC 1!::h 119 E Containment Water Level (Wide Range) 2 1 w it X In Core Thermocouples 4/ core quadrant 2/ core quadrant E 15. U.it V;.t  ::igh "...g; .N etic Ca; "caitor 1 1 (Figh "igh o r.gC - E"r-3C)

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/;t R' Containment Atmosphere - High Range Monitor 1 1 i

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EMF NE 131&. Reactor Vessel level Instrumentation m

EE a. Dynamic Head (D/P) Range 2 1 25 b. Lower Range 2 1 '

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ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS S CHANNEL CHANNEL -

A INSTRUMENT CHECK CALIBRATION -

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1. Containment Pressure R c .

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2. Reactor Coolant Temperature - T H0T and TCOLD (Wide Range) M R

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i ~ 3. Reactor Coolant Pressure - Wide Range M R E 4. Pressurizer Water Level M R o

ro 5. Steam Line Pressure M R

6. Steam Generator Water Level - Narrow Range M R

7. Refueling Water Storage Tank Water Level M R

8. Auxiliary Feedwater Flow Rate M R

9. Reactor Coelant System Subcooling Margin Monitor M R w -

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10 15. Containment Water Level (Wide Range) M R In Core Thermocouples M R ss >M

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55 /R ("rit 2 - E"r-10, 11, 12, 12) 5 5 R. Containment Atmosphere - High Range Monitor M R (EMF-Sla or 51b) mm  !}

• M. Reactor Vessel Level Instrumentation 22 a. Dynamic Head (D/P) Range M R

3. 3. b. Lower Range M R

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6 ATTACHMENT 2 JUSTIFICATION / SAFETY ANALYSIS l

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U.S. Nuclear Regulatory Commission Attachment 2 February 25, 1994 Page 1 JUSTIFICATION The problem that prompted this proposed change is that the instruments listed in T/S Tables 3.3-10 and 4.3-7 do not match entirely with those labeled Post-Accident Monitoring (PAM) in the control room.

The Type, Category and current PAM labeling status of the accident monitoring I instruments that are currently listed in or proposed to be added to the subject l T/S Tables are listed below: )

PROPOSED PROPOSED CHANGE CURRENT CHANGE FOR T/S CATE- PAM LABEL FOR PAM TABLE INSTRUMENT TYPE GORY STATUS

• LABEL i

1. Containment Pressure B 1 Yes I

2. Reactor Coolant Temperature - A 1 Yes T-HOT and T-COLD (Wide Range)

3. Reactor Coolant Pressure - A 1 Yes I (Wide Range) I

4. Pressurizer Water Level A 1 Yes

5. Steam Line Pressure A 1 Yes

6. Steam Generator Water Level - A 1 Yes (Narrow Range) ,

7. Refueling Water Storage Tank A 1 Yes Water Level

8. Auxiliary Feedwater Flow Rate D 2 Yes

9. Reactor Coolant System A 2 Yes Subcooling Margin Monitor Delete 10. PORV Position Indicator D 2 No Delete 11. PORV Block Valve Position Indicator D 2 No Delete 12. Safety Valve Position Indicator D 2 No l 13. Containment Water Level - B 1 Yes (Wide Range)

14. In-Core Thermocouples A 1 Yes Delete 15. Unit Vent - High Range Noble Gas E 2 Yes Delete Monitor (High-High Range - EMF-36)

Delete 16. Steam Relief - High Range Monitor E 2 No (Unit 1 - EMF-24, 25, 26, 27)

(Unit 2 - EMF-10, 11, 12, 13)

17. Containment Atmosphere - High Range C 1 Yes Monitor (EMF-Sla or 51b)

18. Reactor Vessel Level B 1 Yes

a. Dynamic Head (D/P) Range

b. Lower Range Add 19. Neutron Flux - Wide range B 1 Yes Add 20. Containment Hydrogen Concentration C 1 Yes

i U.S. Nuclear Regulatory Commission Attachment 2 j February 25, 1994 Page 2 i

PROPOSED PROPOSED CHANGE CURRENT CHANGE FOR T/S CATE- PAM LABEL FOR PAM TABLE INSTRUMENT TYPE GORY STATUS

• LABEL Add 21. Diesel Generator Cooling Water A 1 Yes Heat Exchanger RN Flow Add 22. Containment Spray Heat Exchanger A 1 No Add RN Flow

• Analog / Digital Gauges and Chart Recorders in Control Room Duke's response to Regulatory Guide 1.97, Revision 2 and both the old and new Standardized Technical Specifications (STS) for Westinghouse Plants were reviewed to determine which instruments should be listed in the T/S Tables and which should be labeled PAM in the control room so that the two places reconcile with each other and simultaneously satisfy the recommendations of this Regulatory Guide. Part of the reason for this confusion is that there was a lack of clear direction from this Regulatory Guide about which instruments should be included in these T/S Tables. The one clear direction from this Regulatory Guide was that all Categories 1 and 2 Types A, B and C should be labeled as PAM.

Regulatory Position 1.4.a of Regulatory Guide 1.97, Revision 2 states in part, ,

"Any equipment that is used for either Category 1 or Category 2 should be designated as part of accident-monitoring instrumentation or systems operation

and effluent-monitoring instrumentation..."

l Regulatory Position 1.4 b of Regulatory Guide 1.97, Revision 2 states, "The instruments designated as Types A, B, and C and Categories 1 and 2 should be specifically identified on the control panels so that the operator can easily discern that they are intended for use under accident conditions."

With respect to position 1.4.b of Regulatory Guide 1.97, Revision 2, Duke Power has been meeting, with some exceptions, this position since our initial response to this Regulatory Guide in 1984.

l The first exception is the Auxiliary Feedwater (CA) Flow Rate. This instrument has been labeled PAM even though it is a Type D and Category 2 instrument. To substantiate why It has been labeled PAM, it is necessary to refer back to Duke's initial response to this Regulatory Guide. concerning the exception to _the CA Condensate Storage Tank (CST) Level recommendation. Duke took the exception that because the Nuclear Service Water (RN) system is the QA1 assured source of water for the CA system, the CA CST level instrumentation does not need to be Category 1 as recommended by the Regulatory Guide. Duke's Category for this instrument is 3. The NRC accepted Duke's position. Because the CA system draws suction from the CA CST, Upper Surge Tanks, Condenser Hotwell, and assured RN system, with numerous indications such as the QA1 RN pump operational status, QA1 RN and CA suction supply source isolation valves (including operators, limit switches, indicating lights), QA1 indication of CA pumps flow to Steam Generators, Category 3 indication of RN pump header discharge flow, and Category 3 CA pumps suction

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,U.S. Nuclear Regulatory Commission Attachment 2 February 25, 1994 Page 3 and discharge pressures, it is more appropriate to label one parameter (CA Flow l Rate) as PAM instead of labeling all parameters, as mentioned above PAM. It is .l therefore intended through this proposed change to keep this instrument labeled I as PAM. l The second exception is the Unit Vent High-High Range Noble Gas Monitor (EMF-36) .

It is not known why it has been labeled PAM while it is a Category 2 Type E instrument. It is therefore intended through this proposed change to delete the PAM label for this instrument.

The third exception is the Containment Isolation Valve Position Indicator. This instrument has never been listed in the T/S Tables nor labeled as PAM in the control room even though it is a Type B and Category 1 instrument. Since there are a lot of containment isolation valve position indicators, plus the fact that these indicators are just indicating lights, not gauges or chart recorders, it is not necessary and justifiable to label all these valve indicators with PAM labels. It is therefore intended through this proposed change to not label these valve position indicators as PAM.

The new STS, Table 3.3.3-1 directs that these T/S Tables should include all Regulatory Guide 1.97, Type A (regardless of Category), and non-Type A (Category 1 only) instruments in accordance with the unit's Regulatory Guide 1.97 Safety Evaluation Report. As a result of this direction, all Regulatory Guide 1.97 variables and Duke's response to these variables were reviewed by Type and Category to make them match with the direction of the new STS. This review i resulted in adding four instruments to and deleting five instruments from the T/S Tables as stated earlier, j With respect to position 1.4.a of Regulatory Guide 1.97, Revision 2 and the .

l direction from the new STS, the Neutron Flux Monitor and Containment Hydrogen  !

l Concentration Monitor are clearly instruments that are used for monitoring accidents; therefore, they should have been listed in the T/S Tables as part of the accident monitoring instrumentation; the PORV, PORV Block Valve and Safety Valve Position Indicators should have been designated as part of the Reactor Coolant system operating instrumentation, and should not have been listed in the

! T/S Tables as part of the accident monitoring instrumentation; the Unit Vent and Steam Relief EMFs should have been designated as part of the effluent monitoring l instrumentation, and should not have been listed in the T/S Tables as part of the accident monitoring instrumentation. Per Regulatory Guide 1.97, Revision 2, the definition for Type D is " provide information to indicate operation of individual safety systems and other systems important to safety". The definition for Type E is " variables to be monitored as required for use in determining the magnitude of the release of radioactive materials and in continually assessing such releases". The new STS does not include these Type D, Category 2 and Type E, Category 2 instruments in its T/S Table 3.3.3-1.

l During the review of Regulatory Guide 1.97 variables and Duke's response to these variables, it was also identified that there were two additional instruments that l have been upgraded by Duke to become Regulatory Guide 1.97, Type A and Category 1

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l U.S. ' Nuclear Regulatory Commission Attachment 2 February 25, 1994 Page 4 1 instruments; however, they have never been listed in the T/S Tables, and only one of them has been labeled as PAM in the control room. These instruments are the D/G Cooling Water HX RN Flow Indicator and the NS HX RN Flow Indicator.

According to the McGuire FSAR (01 May 1992), section 1.11.5.1.1, these additional instruments were not part of or addressed during the initial review, assessment, and implementation phase of Regulatory Guide 1.97, Revision 2; they were not required for post-accident monitoring; however, as a result of the plant modifications, these instruments were determined to be needed for post-accident monitoring. It should be noted that special conditions apply to these two instruments. The RN outlet valve for each of these Heat Exchangers is a motor-operated valve with no automatic actuating capability. If the valve is set to its required position according to the RN system flow balance and power is removed from it to ensure no subsequent movement, then no operator action is required post accident (non Type A variable) . If the valve's flow balance position is fully open, then the QA1 valve position indicating lights may be used by the operator to position the valve. Therefore, in these cases, flow indicator would not be required in order for the operator to position the valve. Per Regulatory Guide 1.97, Revision 2, the definition for Type A is " variables which are monitored to provide the primary information required to permit the control room operator to take specific manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accidents." With respect to this definition, positions 1.4.a and 1.4.b of Regulatory Guide 1.97, and the direction from the new STS, these additional instruments will be listed in the T/S Tables as part of the accident monitoring instrumentation and will be labeled as PAM in the Control room.

Another special condition which applies to the D/G and NS HX RN Flow Indicators involves the operabilities of these indicators and the RN system. This special condition requires Limiting Condition For Operation (LCO) 3.3.3.6.b to be revised i as follows. Existingly, LCO 3.3.3.6.b allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore one of these inoperable RN flow indicators to operable status while LCO 3.7.4.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one inoperable RN loop to operable status before the affected Unit has to be taken out of the LCO's applicable modes. As can be seen in this existing condition, if 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed for restoring one RN loop to operable status, requiring the associated D/G or NS HX RN Flow Indicator to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is unnecessarily restrictive. As revised, LCO 3.3.3.6.b.2 will invoke LCO 3.7.4.a so that the*72 hours, instead of the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, will be l

i allowed to restore the inoperable D/G and NS HX RN Flow Indicators to operable

! status.

SAFETY ANALYSIS The Neutron Flux Monitor, Containment Hydrogen Concentration Monitor, D/G Cooling l

Water HX RN Flow Indicator and NS HX RN Flow Indicator are being added to T/S Tables 3.3-10 and 4.3-7 because they meet the recommendations of Regulatory Guide 1.97, Revision 2 and the new STS. The PORV, PORV Block Valve and Safety Valve l

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U.S. Nuclear Regulatory Commission Attachment 2 February 25, 1994 Page 5 Position Indicators, Unit Vent and Steam Relief EMFs are being deleted from the T/S Tables because they do not meet the recommendations of Regulatory Guide 1.97, Revision 2 and the new STS. The PAM label for the Unit Vent High-High Range EMF-36 is being deleted from the control room because it does not meet the recommendation of position 1.4.b of the Regulatory Guide. The PAM label for the Containment Spray HX RN Flow Indicator is being added to the control room because it meets the recommendation of position 1.4.b of the Regulatory Guide.

This proposed change does not involve any change in the type, category, ' hardware or setpoint of any of the involved instruments and involves only the designation of which of these instruments should be listed in the T/S Tables and labeled as PAM in the control room; therefore, this proposed change does not affect the current design, operation, and safety significance of these instruments. ,

As-the same instruments will be listed in the T/S Tables and labeled as PAM in the control room, this will provide consistent information to plant personnel, especially the operators who need to discern which instruments are intended for their use under accident conditions.

Based on the facts stated above, it is concluded that this proposed change does not have any adverse safety impact on McGuire.

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ATTACHMENT 3 ,

4 SIGNIFICANT HAZARDS CONSIDERATION

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U.S. Nuclear Regulatory Commission Attachment 3 February 25, 1994 Page 1 1 The proposed change shall be deemed not to involve a significant hazards l consideration if there is no positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

4 RESPONSE: No This proposed change does not involve any significant increase in l the probability or consequences of any accident previously evaluated because no changes in the types, categories, hardwares and setpoints of the instruments involved were made; only the designation of which instruments should be listed in the T/S Tables and labeled as PAM in the control room is changed through this proposed change.  !

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2. Will operation of the facility in accordance with this proposed j change create the possibility of a new or dif ferent kind of accident from any accident previously evaluated?

1 RESPONSE: No  !

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This proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because no changes in the types, categories, hardwares and setpoints of the instruments involved were made; only the designation of which instruments should be listed in the T/S Tables and labeled as PAM in the control room is changed through this proposed change. ,

3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

RESPONSE: No This proposed change does not involve a significant reduction in a margin of safety because no changes in the types, categories, hardwares and setpoints of the instruments involved were made; only the designation of which instruments should be listed in the T/S Tables and labeled as PAM in the control room is changed through this proposed change.

Based on the above, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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