ML20080C742

Proposed Tech Specs Table 3.3-6 Action Statement Re Control Room Air Intake at Times When Radiation Monitors (EMF-43A & 43B) Inoperable

ML20080C742
Person / Time
Site:	McGuire, Mcguire
Issue date:	12/07/1994
From:	DUKE POWER CO.
To:
Shared Package
ML20080C740	List: ML20080C737 ML20080C742
References
NUDOCS 9412200116
Download: ML20080C742 (10)

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ATTACHMENT 1 DLKE POWER COMPANY McGEIRE NUCLEAR STATION l

PROPOSED REVISION TO THE - ,

TECHNICAL SPECIFICATION l 4

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TABLE 3.3-6 (Continued)

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RADIATION MONITORING'INSTRtNENTATION FOR PLANT OPERATIONS -

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e c CHANNELS -CHANNELS APPLICA8LE ' ALARM / TRIP. .

TO TRIP / ALARM OPERABLE' MODES SETPOINT.  ; ACTION t

5 MONITOR  :

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y 6. Control Room Air .1 per station All 27: ,

, , Intake Radioactivity- station pCi/ml g High '

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-With fuel in the fuel storage areas.or fuel building. y  :. s With-irradiated fuel in the fuel storage areas or fuel building. --

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• • • Must-satisfy the requirements of McGuire Selected Licensee Commitment 16.11-6.

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EACTION' STATEMENTS m

l ACTION 26 ' With less than'the Minimum Channels OPERA 8LE requirement, operation may continue '

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provided the containment purge valves are maintained closed.

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$$ ACTION 28 - With less than the-Minimum Channels OPERABLE requirement, operation may continue for . _

ss up to 30 days provided;anLappropriate portable continuous monitor with the same'Alara .

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,2 Setpoint is provided in the_ fuel: pool area. Restore the: inoperable' monitors to'

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OPERABLE status within 30 days;or suspend ~allJoperations involving fuel' movement in. .

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ACTION.29 -u Must satisfy the ACTION _ requirement for Specification 3.4.6.1.-  ;

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e* - ACTION 30 - ~ With 'less than the. minimum channels OPERA 8LE requirement,: operation may continue - ~

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p& 2 provided the Fuel Handling Ventilation Exhaust _ System requirements of Specifica -- -

' 7. y tion 3/4.9.11 are met. -

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\ ACTION'27 + With th'e numberfof channel's,less,thanIths l ,

Minimum Channel OPERABLELrequirement,.

' 'i immediately initiate corrective' actions'.toi s y ~

restore the inoperable'instrumentLto' OPERABLE ' ,". . < .:,

L status. If'the inoperable.: instrument'hastnot

. been1 restored-to OPERABLE status 1within'seven' ,

calendar > days,-a special1 report.;shall be cwritten >

' detailing the.cause-ofJthe inoperability, and' the~ expected date of.the. return toLoperable status.of the inoperable instrument.

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b ATTACHMENT 2 i

l DUKE POWER CO MPANY .

McGUIRE NUCLEAR STATION h

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TECHNICAL JUSTIFICATION 4

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• b ATTACIDEEarr 2 Description of Proposed Changes, Justification, and' Safety Analysis Proposed Chance.:

The proposed change to.the McGuire Nuclear Station. Technical  ;

Specifications seeks to modify the. action statement concerning-the Control Room Air Intake at times when the radiation monitors (EMF-43A and 43B) are inoperable. The current' action.

statement requires isolation of the intake flow path when the associated EMF is inoperable.

The proposed change would allow the intake path to remain open while the EMF is being repaired. The. proposed action statement, while allowing the dampers to' remain open, would require the immediate initiation of corrective actions to restore the affected EMF to operable status and the generation of a special report in the inoperability is not corrected-within seven calendar days.

Justification:

As described in Section 6.4 of the Final Safety, Analysis Report (FSAR), the Control Area Ventilation (VC) system is designed as an Engineered Safety Features system, to maintain the . -

habitability requirements in the control Room during both normal operation and a Design Basis Accident (DBA). The-proposed change will have no impact during normal operation since the airflow through the Control Room is 100%

• recirculated.

Section 15.6.5.3 of the FSAR, Environmental Consequences for Loss-of-Coolant Accidents-(LOCA), Control Room Operator-Dose, states in part that the maximum postulated dose to a. control ,

Room Operator is based on the releases of a DBA. 4 The dose analysis to the Operators as a result of a DBA assumed that all outside air brought into the Control Room is-contaminated during the post accident operation oflthe VC system. It is also assumed that some amount of contamination will remain in the ventilation air after the filtration process. The results of the analysis indicated that the doses to the Control Room Operators were within the guidelines of General Design Criteria 19.

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To minimize theLintroduction of unfiltered contaminant entry.

into the Control. Room during an accident, the VC system pressurizes the Control Room to. greater than or equal to 0.125 r inches water gauge (relative to outside atmospheric' pressure).

In order to. develop and maintain the required pressure, at least one of the outside' air intakes must be open.

Following a DBA,.outside air would be taken from both air intake locations. Isolation of a given intake due to the presence of contaminated air is performed manually by the

>: Control Room Operators. The radiation monitors are utilized-to alert the Control Room Operators of the presence of airborne activity within a particular intake train. Based.on the g~

information from.the radiation monitors, the Control Room Operators will manually isolate the contaminated intake (or the intake with the highest level of radioactivity). At least two of the four outside air intake will remain open in order to maintain pressurization of the Control Room.

High radiat3on is detected by radiation monitors EMF-43A and EMF-43B, located at the intakes of Trains A and B respectively.

Each monitor is currently configured to alarm on a radiation level of less than or equal to 3.4 x 10-4 micro curies per.

milliliter. If only one train intake receives a high radiation alarm, the operator is procedurally instructed to manually close that intake. The remaining train intane should continue to support the operation of the Control Room and associated subsystems. The isolated train intake should, eventually be purged. In the event that the intakes for both trains are radioactively contaminated, the operator will select the least contaminated intake and Control Room pressurization will be maintained as ne sad. The most contaminated intake can be returned to serl .e at the operators' discretion.

.In the event tha. One or both radiation monitors are out of service, the proposed Technical Specification change requires that action be taken immediately to return the monitor (s) to service. Furthermore, the proposed change deletes the requirement to isolate the outside air intake with the inoperable monitor within one hour; therefore, the outside air intake could remain open under the provision of the proposed-change. By allowing the outside air intakes to remain open, the ability to pressurize the Control Room'is' preserved, other means of monitoring the radioactivity will be utilized in the event that radiation monitors EMF-43A and EMF 43B are inoperable and an accident'resulting in an Engineered Safeguards Actuation accompanied by contaminated air near the outside air intakes occurs.

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'Any event that'would result in significant e'ffluent: releases would require the activation of the Emergency Response.

Organization. -This activation would provide the necessary resources that could not only monitor.the contamination levels outside surrounding,the air intakes, but also the radiation

' levels within the Control Room,. and thus-the dose toithe

' operators. By these means, the dose to'the Control Room operators can be' maintained below the guidelines of General Design Criteria 19, given the inoperability.of. EMF 43A/ EMF-43B.

1 Safetv Analysigi The pressurized air flowing into the Control Room passes' through one of two trains of a safety related Absolute and Carbon filter system which is designed to protect against the maximum postulated radiological dose to a Control Room' Operator during a Design Basis Accident.

Radiological contaminants are removed by the filtration system so that clean air is supplied to'the Control Room. This air pressurizes the Control Room and prevents the ingress of possible contaminated air from the Turbine / Auxiliary Buildings or the surrounding atmosphere.

The McGuire. Accident Analysis assumes that all outside air brought into.the Control Room is contaminated during post accident VC operation. Based on. dual' inlet operation, the allowable dose will not be exceeded even though a contaminated inlet is not closed during a DBA. When'the~ radiation-

monitor (s) is returned to operable status, a determination may be made as to which, if either, inlet should be closed.

Operation in this manner is within the bounds of the' accident '

analysis.

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ATTACHMENT 3 i

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DUKE POWER COMPANY. '

McGUIRENUCLEAR STATION 1 a

1 NO SIGNIFICANT HAZARDS CONSIDERATIOXANALYSIS 1 .

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t O ATTACHNENT 3 NC SIGNIFICANT HAEARDS CONSIDERATION EVALUATION

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The-following analysis is provided in accordance.with 10'CFR 50.91 to determine if-the proposed change will' involve a-significant hazard consideration. This determination has been made using the criteria of 10 CFR.50.92.

1. The proposed amendment would not involve a-significant' ,

increase in the probability or' consequences of'any P accident previously evaluated in the FSAR.

The amendment change will ensure correct Control Room' Ventilation system alignment in order to mitigate the consequence of a Design Basis LOCA as described in FSAR Section 15.6.5.3, Environmental Consequences-of'a Loss of-Coolant Accident-3, Control Room Operator Dose.

The amendment change will. permit the intake to remain open and will specify that action to repair the affected monitor shall be taken immediately. The change itself is not considered to be an initiator of any previously evaluated accident. Maintaining the VC intake open with an inoperable monitor.will not result in any. accidents-that have not been previously evaluated. The implementation of immediate actions to repair the inoperable monitor does not in itself represent any accidents that have not been previously evaluated.

Therefore, the proposed Technical Specification change does not increase the occurrence probability of previously evaluated accidents.

The change to permit maintenance of open intakes will not increase the consequences of any previously evaluated accidents. The proposed amendment change is consistent with the original Safety Analysis.concerning the Dose to the iperators.

The analysis determined that the-Doses to-the Operators were within acceptable ranges given the assumptions that the intakes would remain open and the contaminated air was processed through a Safety Related filter train prior to introduction into the Control Room. The proposed change remains consistent with this analysis and does not change the assumptions or methodology utilized to assess

. the Doses to the Operators for a hypothesized DBA; therefore, the proposed amendment change will not increase the consequences of any previously evaluated accident.

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2. The proposed' amendment would~not create the possibility of'a now or different' kind of accident not previously

evaluated.

The proposed change will not modify, delete, or' add any systems:or components; therefore,.no'new-failure modes or accidents scenarios will be created.

No test or experiments'will be revised; therefore, .no-new

. initiating events or;unanalyzed condition will be-

' created. Administrative changes to surveillance procedures will be minor and will not create a safety concern.

p 3.. No significant reduction in a margin of safety will occur.

The proposed amendment change requiring immediate action to initiate repairs to an inoperable monitor does not impact existing Safety Margins. Since requirements for immediate corrective action does not currently exist within the. Specification, the change will enhance the availability of the subject monitors.

The proposed amendment does not change / impact any assumption or methods utilizedito assess the doses to the operators for a hypothetical worst-case DBA.

Accordingly, the proposed amendment does not reduce any -

safety margins.

l Based ~on the above evaluation, Duke Power Company concludes that the proposed Technical Specification amendment does not involve a Significant Hazards Consideration. -

Environmental Impact Analysis The proposed technical specification amendment has been r reviewed against the criteria of 10CFR51.22 for environmental l considerations. The proposed amendment does not involve a '

significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase  :

individual or cumulative occupational radiation exposure.

Therefore, the proposed amendment meets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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