ML20080F790

Application for Amends to Licenses NPF-9 & NPF-17 to TS Re Amends That Allow Analog Channel Operational Test Interval for Radiation Monitoring Instrumentation to Be Increased from Monthly to Quarterly

ML20080F790
Person / Time
Site:	Mcguire, McGuire
Issue date:	01/18/1995
From:	Mcmeekin T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20080F796	List: ML20080F790 ML20080F798
References
NUDOCS 9501310140
Download: ML20080F790 (11)

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I DukeIbwer Company T. C Mdians McGuire Nuclear Generation Department %cehesident 12700Hagers ferryRoad(MG01VP) (704)8754800 lluntersvale, NC2807M985 (704}9754809 Fax DUKEPOWER Date: January 18,1995 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

Subject:

McGuire Nuclear Station, Units I and 2 Docket Nos.

Proposed Technical Specifications Changes Increase in Radiation Monitoring Instmmentation Surveillance Interval from Monthly to Quarterly Gentlemen:

Pursuant to 10CFR50.4 and 10CFR50.90, p*tached are license amendment requests to Appendix A, Technical Specifications, of Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2, respectively. The requested amendments allow the analog channel operational test interval for radiation monitoring instminentation to be increased from monthly to quarterly. The proposed amendments are consistent with NRC staff recommendations and guidance contained in NUREG-1366, " Improvements to Technical Specification Surveillance Requirements" and Generic Letter 93-05 "Line-Item Technical Specifications Improvements to Reduce l Surveillance Requirements for Testing During Power Operation."

l Attachment I contains a background and description of the enclosed amendment request.

Attachment 2 contains the required justification and safety evaluation. Pursuant to 10CFR50.91, Attachment 3 provides the analysis performed in accordance with the standards contained in10CFR50.92 which concludes that the requested amendments do not involve a significant hazards consideration. Attachment 3 also contains an environmental impact analysis for the requested amendments. Attachment 4 contains the marked-up technical specification amendment pages for McGuire. Duke Power Company is forwarding a copy of this amendment request package to the appropriate North Carolina state official.

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Document Control Desk Page 2 Date: January 18,1995 Relaxation of the annalog channel operational test interval for radiation monitoring instrumentation from monhtly to quarterly will result in an increase in the availability of ;

the instruments. This amendment request is also being submitted as a Cost Beneficial  ;

Licensing Action (CBLA) item. Approval and implementation of this amendment request is expected to result in substantial savings in resources relative to conducting i surveillance activities for radiation monitoring instrumentation. Accordingly, timely I approval of this proposed amendment is requested. An implementation date of 30 days l from the date of NRC approval is requested. 4 Should there be any questions concerning this amendment request or should additional information be required, please call Dwin Caldwell at (704) 875-4328.

I Very truly yours, {

f gM1 m i T. C. McMeekin '

LJR/s l i

Attachments l xc(W/ Attachments): ,

S. D. Ebneter, Regional Administrator  ;

Region II  ;

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George Maxwell , Senior Resident Inspector  ;

R. E. Martin l ONRR i

Dayne Brown, Chief Division of Radiological Protection, N.C.

American Nuclear Insurers INPO Records Center

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Document Control Desk Page 3 Date: January 18,1995 T. C. McMeekin, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the McGuire Nuclear Station License Nos. NPF-9 and NPF-17 and that all statements and matters set forth therein are true and correct to the best of his knowledge.

FOLM' ,,;

T. C. McMeekin, Vice President Subscribed and sworn to before me this /[ day of [AM ,1995.

Yb k a ). Il30)JA / u N/ary blic

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My commission expires:

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Document Control Desk Page 4 Date: January 18,1995 l

I bxc: (with attachments)

A. V. Carr J. E. Snyder G. A. Copp Z. L. Taylor J. W. Boyle ,

ELL-EC050 G. A. Frix <

Reg. Comp. File: Technical Specifications )

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ATTACIIMENT I ilACKGROUND AND DFSCRIPTION OF AMENDMENT REQUEST l

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Itackground Radiation monitoring (EMF) instrumentation at McGuire is divided into basic types: process ,

radiation monitors and area radiation monitors. l l Process radiation monitors monitor primary and secondary systems within the station during normal operations, including anticipated operational occurrences. They provide continuous monitoring of radioactive liquid and gas discharge to the environment. They also provide interlocks to automatically terminate discharge from waste systems at preset activity levels.

Finally, they provide monitoring of airborne and liquid activity in selected locations and effluent paths during postulated ioss of coolant accidents.

l Area radiation monitors indicate radiation levels at various locations throughout the station where personnel expasure is likely. In addition, they sound local and Control Room alarms when

, radiation levels exceed the respective alarm setpoint. ,

l Technical specifications delineate surveillance requirements for certain EMFs at McGuire.

Included in the specified surveillance requirements is a monthly an.-Jog channel operational test. j l

In December 1992, the NRC issued NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements." In Section 5.14 of the NUREG," Radiation Monitors," the NRC recommended that the frequency of radiation monitor channel functional tests be changed from monthly to quarterly. This would result in increased availability of radiation monitoring equipment, as well as decreased licensee burden relative to testing requirements.

On September 26,1993, the NRC issued Generic Letter 93-05,"Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." In this generic letter, the NRC transmitted guidance to assist licensees in preparing license amendment requests to implement the recommendations of NUREG-1366 as line-item technical specifications improvements.

Descrintion of Amendment Request in Technical Specification Table 4.3-3, Radiation Monitoring Instrumentation for Plant Operations Surveillance Requirements, the frequency of the analog channel operational test specified is changed from monthly (M) to quarterly (Q) for all EMFs listed in the table.

No changes to the associated liases section for this technical specification are required.

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t ATTACIIMENT 2 JUSTIFICATION AND SAFETY EVALUATION l

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l Justification and Safety Evaluation The proposed amendments are consistent with the NRC staff position set forth in NUREG-1366 and also with the guidance transmitted in Generic Letter 93-05. In addition, they are also j compatible with observed plant operating experience as it pertains to the surveillance history of the radiation monitors at McGuire.

l McGuire personnel performed a review of a t. ample of completed analog channel operational test procedures for the radiation monitors listed in McGuire's Technical Specifications. Approximately 12 consecutive monthly tests weie analyzed by reviewing text descriptions of work performed via McGuire's computer based Work Management System (WMS) and by reviewing test data from several completed procedures per channel via microfilm. These procedures had been completed in calendar years 1993 and 1994. This emphasized the most recent test history of the radiation monitors. No problems were found which would preclude lengthening the surveillance interval for Analog Channel Operational Tests from monthly to quanctly. The radiation monitor performance history as observed over the review period is typical of performance history over the plant operating life. The completed analog channel operational test procedures are available for NRC inspection.

The proposed amendments will not be detrimental from a safety standpoint The change in surveillance frequency for the radiation monitors listed in Technical Specification Table 4.3-3 from monthly to quanerly will not affect any accident analyses contained in Chapter 15 of the Final Safety Analysis Repon. The data reviewed for this amendment request supports this conclusion.

Funher, no credit is taken in the plant accident analyses for any automatic actuation function generated as a result of a signal generated by a monitor covered by this amendment. Finally, changing .he surveillance interval from monthly to quanerly will increase the availability of the affected radiation monitors as indicated in NUREG-1366 and Generic Letter 93-05.

ATTACIIMENT 3 NO SIGNIFICANT IIAZARDS CONSIDERA'IION DETERMINATION AND ENVIRONMENTAL IMPACT ANALYSIS

No Sienificant Ilarards Consideration Determination As required by 10CFR50.91, this analysis is provided concerning whether the requested amendments involve significant hazards considerations, as defined by 10CFR50.92. Standards for determination that an amendment reques involves no significant hazards considerations are if operation of the facility in accordance with the requested amendment would not: 1) Involve a significant increase in the probability or consequences of an 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 significant reduction in a margin of safety.

The requested amendments increase the surveillance interval (i.e., decrease the analog channel operational test frequency) of radiation monitoring instrumentation (EMFs) from monthly to quarterly.

In 48FR14870, the Commission has set fonh examples of amendments that are considered rot likely to involve significant hazards considerations. Example vii desc-ibes a change to make a license conform to changes in regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations. The requested amendments are similar to example vii in that they result in minor changes to plant surveillance requirements and are consistent with the existing NRC position and guidance contained in NUREG-1366 and Generic Letter 93-05. While the issuance of NUREG-1366 and Generic Letter 93-05 does not constitute a change in existing regulations. it nevertheless establishes the NRC staff's position conceming the acceptability of increasing the surveillance interval for radiation monitoring instrumentation from monthly to quanerly. The requested amendments are consistent with the position of NUREG-1366 and with the guidance of Generic Letter 93-05.

Criterinitl The requested amendments will not involve a significant increase in the probability or consequences of an accident previously evaluated. Decreasing the frequency of the radiation monitor analog channel operational test from monthly to quarterly will have no impact upon the probability of any accident, since tN radiation monitors are not accident initiating equipment.

Analysis of the previous test data, as described in Attachment 2, shows that no significant degradation of performance is to be expected by the decrease in frequency. Therefore, the requested amendments will have no adverse impact upon the consequences of any accident.

Criterica2 The requested amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated above, the radiation monitors are not accident initiating equipment. No new failure modes can be created from an accident standpoint. The plant will not be operated in a different manner.

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The requested amendments will not involve a significant reduction in a margin of safety. Plant safety margins will be unaffected by the proposed changes. No safety equipment which is taken credit for in accident analyses will be affected by the requested amendments. The availability of the affected radiation monitors will be increased as a result of the proposed amendments because the monitors will not have to be made enavailable for testing as frequently. In addition, radiation monitor operating experience supports the proposed amendments. Finally, the proposed amendments are consistent with the NRC position and guidance set forth in NUREG-1366 and Generic Letter 93-05.

Ilased upon the preceding analyses, Duke Power Company concludes that the requested amendmcras do not involve a significant hazards consideration.

EntiremmentalImnact Analysis De proposed technical specification amendment has been reviewed against the criteria of 10CFR51.22 for environmental 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 exposures.

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

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