ML20077E219

Proposed Tech Specs,Changing Time Limit within Which Inoperable Radiation Monitor Becomes Reportable Per Tech Spec 6.9.2

ML20077E219
Person / Time
Site:	Grand Gulf
Issue date:	05/30/1991
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20077E208	List: ML20077E206 ML20077E211 ML20077E219
References
NUDOCS 9106060225
Download: ML20077E219 (8)

Text

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4 Attachment 2 to GNRO-91/00038 I

PROPOSED CHANGE TO THE OPERATING LICENSE

-REVISIONS TO TECHNICAL SPECIFICATION Table 3.3.7.5-1 (GGNSPCOL-91/09) l l

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-PCOLRR/SCMPFLR - 5 9106060225 910530-PDR ADOCK 05000416 P PDR _

Attachment 2 to GNRo-91/00058 A. SUBJECT

1. NL-91/08 Technical Specification Compliance with Generic Letter 83-36.

2. Affected Technical Specifications:

a. Accident Monitoring Instrumentation, Table 3.3.7.5-1 (Items 8 and 9) - pages 3/4 3-74 and 3-75

b. Accident Monitoring Instrumentation, Table 3.3.7.5-1 (Action 81) - page 3/4 3-75 i

B. DISCUSSION

, 1. ecification (TS) 3.3,7.5 (Table 3.3.7.5-1, GGNS Items 8 Technical and 9), Sp' Accident Monitoring Instrumentation,"

specifies OPERABILITY requirements for the drywell and containment hydrogen concentration analyzers and monitors (H, Monitors) including ACTIONS to be taken in the event one or more channels are inoperable. The proposed change for the analyzers and monitors would increase the amount of allowed outage time permitted before a plant shutdown is required.

2. GGNS TS 3.3.7.5 (Table 3.3.7.5-1, Action 81), " Accident Monitoring Instrumentation," specifies OPERABILITY requirements for several accident range radiation monitors (rad monitors) including ACTIONS to be taken in the event one or more rad monitors are inoperable. The proposed change would increase the time limit at which an inoperable rad monitor would become reportable per TS 6.9.2.

3. Presently, TS for the above instrumentation is not consistent with the. guidance provided in NRC Generic Letter (GL) 83-36.

Therefore, Entergy Operations, Inc. proposes to revise the TS ACTIONS specified for the above accident monitoring instrumentation in Table-3.3.7.5-1 such that the ACTIONS are consistent with the guidance provided in NRC GL 83-36.

C. JUSTIFICATION

1. The design basis of all engineered safety features is to mitigate accidents and does not take into consideration operator action or assistance for the first ten minutes of the accident. This assumption makes it mandatory that all rotective actions necessary in the first ten minutes be p' automatic." 'Therefore, information for operators to base actions upon from post-accident instrumentation is not required for at least ten minutes following an accident.

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Attachment 2 to GNRo-91/00058

2. In accordance with TS 3.3.7.5 and UFSAR commitments contained in Section 7.5.1.2.8, the containment /drywell hydrogen monitoring systems are required to provide continuour indication and alann capabilities in the control room of hydrogen concentrations in the containment and drywell atmosphere following a postulated LOCA.

The system provides operators with the capability to assess the extent of hydrogen mixing or generation in the containment and drywell . The system provides no automeic safety system actuations, it strictly performs a monitoring function.

In the event the Hydrogen Monitoring System is inoperable during the course of an accident, approved plant procedures specify other means by which the hydrogen concentration of the containment and drywell atmosphece can be obtained by sampling and analysis.

3. The radiation monitors provide indications of radiation levels inside the drywell and containment,_ along with various ventilation effluents during accident conditions.

4. The operability of these and other accident monitoring instrumentation ensures that sufficient infonnation is available to operators on selected plant parameters to monitor and assess important variables following an accident.

5. is The existing consistent withTS theassociated with accident recommendations monitoring"TMI-2 of NUREG-0578, Lessons Learned Task Force Status Report and Short-Term Recommendations". In 1983 a Generic Letter was issued on the subject of NUREG-0737 related TS (GL 83-36). GL 83-36 identified several TS requirements which could be relaxed. The relaxation of these TS requirements would provide GGNS sufficient time to perform required maintenance and surveillance testing without increasing the consequences of an accident.

6. The net effect of the requested changes is to extend the allowed out of service time of the Hg monitors and in addition extend the time for which a Special Report is required to be written for inoperable radiation. monitors. As stated above, the instrumentation serves no automatic accident mitigation function, but provides operator information following a postulated accident. rhe additional time is justified based on the compliance with the requirements of the ACTIONS and the heightened awareness _of the condition of the system when the LC0 is entered into the Control Room LC0 Log. The imposition of_the Special Report requirement does not aid in restoring the instrument to OPERABILITY but only imposes an additional administrative task with no commensurate improvement in safety.

Generic Letter 83-36 supports this conclusion.

PCOLRR/SCMPFLR - 7

LAttachment 2 to GNRO-91/00058 D. N0 SIGNIFICANT HAZARDS CONSIDERATION

1. Entergy Operations, Inc. is proposing that TS Tabic 3.3.7.5-1

be revised to change the allowed outage times for.the-i containment and drywell hydrogen analyzers and monitors. The proposed changes also would change the time limit at which an

inoperable radiation monitor becomes reportable per TS 6.9.2.

The proposed changes are consistent with the guidance of GL j 83-36.

2. The Commission has provided standards for vetermining whether a

no significant hazards consideration exist. as stated in

10CFR50.92(c). A proposed amendment to an operating license c involves no significant hazards if operation of the facility in accordance with the proposed amendment would not

(1) involve a significant increase in the probability or consequences of an l accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a signi_ficant reduction in j a margin of safety.

3. GGNS has evaluated the no significant_ hazards considerations in its request for a license amendment. In accordance with 10CFR50.91(a), GGNS is providing the-following analysis of the proposed amendment against the three standards in 10CFR50.92:

a. No significant increase in the probability or consequences of an accident previously evaluated results from this

change.

The malfunction or misoperation.of the instrumentation affected by the proposed change.is not considered to be an 1 initiating event in any accidents evaluated in the.UFSAR.

The instrumentation serves only as a source of information.

' for the operator. following a postulated accident. The analyses do-not. rely upon operator actions-in lieu of automatic safety--system actuation-during the first ten minutes of any accident and no credit is taken in the analyses for post accident instrumentation. Although

< operator actions are' relied upon to mitigate' degradation

+

of containment due to hydrogen ~ concentration,-approved Emergency Operating Procedures are currently in use which give specific guidance in-the event the H, Monitors are

1. not available. Compliance with the proposed ACTIONS of-the TS provides adequate compensatory measures (e.g. Post Accident Sampling System (PASS)1 samples, grab samples)'

given:the role of the systemsein the overall safety of the plant.

The proposed change, therefore, does.not significantly increase the probability or. consequences _of an. accident previously evaluated.-

PCOLRR/SCMPFLR - 8 x .  ;. . a. . . .

'9 Attachment 2 to GNRo-91/00058 4

b. This change would not create the possibility of a new or different kind of accident from any previously analyzed.

Th( affected instruments provide monitoring capability onlj. No new modes of plant operations are introduced by the proposed changes. The existing instrumentation will remain available to provide operators information.

4 Therefore, the revested change will not create the l

possibility of a new or different accident from any previously analyzed.

c. This change would not involve a significant reduction in the margin of safety.

The Emergency Procedure, which addresses hydrogen control, gives guidance in the event the H, monitors are not available. The procedure references the PASS as a means of obtaining an adequate atmospheric sample of the_ drywell and containment. Thtrefore, the proposed change would not ,

affect the ability to obtain an indication of hydrogen '

concentration.

I The proposed changes do not affect the methodology used in '

the offsite dose analysis nor the acceptance criteria associated with any accident analysis.

Therefore, this change will not involve a reduction in the margin of safety. '

4. Based on the above evaluation, Entergy 0_oerations has concluded that operation in accordance with the proposed amendment involves no significant hazards considerations.

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c) .

O C TABLE 3.3.7.5-1 e >

2 ACCIDENT M NT3T10N -

g APPLICABLE KINIMIM D r- OPERATImAL MgutKD sesma CnnsesELS C=

T INSTRISENT C85tT195 0F rummasts OPERABLE A2TI0tt g 1. Reacter Wesesi Pregours 1, 2, 3 2 1 88 Z 2. ReacterVoedi11sterLevel 1, 2, 3, 4, "i 2 1 82 H 3. Suppresslee Peel Ideter Level 1, 2, 3

• 2 1 80 i

4. Sgpression'Seel Mager Temperature 1, 2,(3 ,6, 1/secter 6, 1/ sector 80

5. Brywell/r - q 9f fferential Pressure 1, 2, 3 2 1 30

6. Drywell Prosegsp% 1,2,3 2 1 80

7. Brywell and Centrol Red Brive Cavity Temperature 1, 2, 3 2 (each) 1 (each) 80

8. Conzainneet Hydrogen Concentratten Analyzer end Monitor 1, 2, 3 2 1 O '

9. Drywell Hydrepa Concentration Analyzer and y

Meniter 1, 2, 3 2 1 gd

10. Centalaner.1 Pressere (wide and norrent range) 1,2,3 2 (each) 1 (each) 80 i

11. Containment .Alr Tamperatere 1, 2, 3 2 1 80

{

12. Safety / Relief Valve Tall Pipe Pressure Switch Positten Indicators 1, 2, 3 1/ valve 1/ valve 80

13. Contaissent/0rywell Area Radiation Moalters 1,2,3,4,5 2 2 81

14. Contaisument Ventilation Exhaust Radiation Monitor 1,2,3,4,5 1 1 81

15. 'Off gas and Radweste 51dg. Ventilation Exheest Radiation Monitor 1,2,3,4,5 1 1 81

16. fuel Handling Area Ventilatten Exhaust ,

Radiation Moniter 1,2,3,4,5 1 1 81

17. Turbine 51dg. Ventilation Exhaust Radiation

( Monitor 1, 2, 3 1 1 81 7

1. 18. Staney Gas Treatment System A & B Estuust Radiation Monitors I/each 1/each 81

1. Each for containment and drywell.

• idhen its associated train of the staney gas treatiment , system is required ogwrable (Ret i66.1)

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' TABLE 3.3.7.5-1 (Continued)

ACCIDENT MONITORING INSTRUMENTAi!ON ACTION STATEMENTS ACTION B0 -

a. With the number of OPERABLE accident monitoring instrumentation 4

i channels less than the Required Number of Channels shown in Table 3.3.7.5 1, restore the inoperable channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

, b. With the number of OPERABLE accident monitoring instrumentation 4

channeis less than the Minimum Channels OPERABLE requirements of Table 3.3.7.5-1, restore the inoperable channel (s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 /> and be in COLD SHUTOOWN within the

$ next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 81 -

4 With the number of OPERABLE accident monitoring instrumentitthf xhd ,.{ A + nnels less than required by the Minimum Channels OBERABLE

" requ ent, either restore the inoperable chantiel($1 to OPERABLE s s within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:

L

a. Initiate the eplann pr \ Iternys-mehodofmonitoringthe

,. appropriate parameter (s),

b. Prepare and suyb i a Special Report to Commission pursuant to Specifi. cation 6.9.2 within 14 days foll the event ou hig the action taken, the cause of the inop lity and ens and schedule for restoring the system to OPE ACTION 82 - For OPERATIONAL CONDITIONS 1, 2, 3

a. With the number of OPERABLE accident monitoring instrumentation channels less than the Required Number of Channels shown in Table 3.3.7.5-1, restore the inoperable channel (s) ~.o OPEP.ABLE status within 7 days or be in at least HOT SHUTDOWN within the ,

next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

b. With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3.7.5-1, restore the inoperable channel (s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in COLD S4UT00WN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

For OPERATIONAL CONDITIONS 4, 5 -

With the number of OPERABLE accident mon'toring-instrumentation channels less than required by the Minimum Channels OPERABLE require-ment, either restore the inoperable chan;#el(s) to OPER/ ALE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or initiate the preplanned alternate method of In.n d gj monitoring the appropriate parameter (a,). _

GRAND GULF-UNIT 1 3/4 3-75 b.hd Al . _ ,

!' , yL-91/08 l

l Insert A i

i l With the number of OPERABLE channels less than required by I the minimum channels OPERABLE requirements, initiate the preplanned l

alternate method of monitoring the appropriate parameter (s) within 72  !

hours, and j a. citherrestoretheinoperablechannel(s)toOPERABLEstatus j within 7 days of the event, or b, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability and i the plans and cchedule for restoring the system to OPERABLE

status.

2 Insert B i

i ACTION 83

a. With the number of OPERABLE channels one-less than the 4

required number of channels shown in Table 3.3.7.5-1, restore l the inoperable channel to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in

! COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4

b. With the number of OPERABLE channels less then the mininiumi l channels.0PERABLE requirements of Table 3.3.7.5-1, restore at 2

-least one channel to OPERABLE status within 7 days or be'in at

. least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in COLD-SilVIDOWN-within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l M OLRR/SCMPFLR - 10 u