ML20138C873
| ML20138C873 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/21/1985 |
| From: | Leonard J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20138C871 | List: |
| References | |
| NUDOCS 8510230082 | |
| Download: ML20138C873 (6) | |
Text
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Long Island Lighting Company i
Operating License NPF-36 Docket 50-322 License Change Application 1 i
I The License Change Application requests modifications to Operating License NPF-36 for the Shoreham Nuclear Power Station 1.) to convert one of the two Reactor Building Standby Ventilation System low range noble gas radiation monitors to a plant vent stack low range noble gas radiation monitor, and 2.) to modify paragraph 2.C (8) in anticipation of an approval of LILCO request (s) for an extension of the November 30, 1985 date
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contained in 10 CFR Part 50.49.
I Long Island Lighting Company By p
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.A Jcyn D.
Leonard, Jr.
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Vi:e President N
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Subscribed and sworn to before me this 4/
day of October 1985.-
I 1iNDA A. CRATTY NOTARf FLEuC. State et New York No.49i6767
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d Cernman Ex;xres March 30,19',
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My Commission Expires:
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1.0 LICENSE CHANGE APPLICATION 1 The following changes to the Facility Operating License NPF-36 are requested in order to (a) allow completion of a station modification that will provide the Shoreham Nuclear Power Station - (SNPS) with a low range noble _ gas stack vent radiation monitor in conformance with the design and qualification criteria of Category 2 instrumentation described in-Regulatory Guide 1.97, Rev.
2, and (b) modify i
paragraph 2.C. (8).
I
2.0 DESCRIPTION
OF CHANGES 2.1 Accident Monitoring Instrumentation A.
Revise Technical Specification Table 3.3.7.5-1 as follows (see Attachment I):
a)
Change the " Required Number of Channels" from two (2) to one. (1) for instrument item number 13 (Low Range Reactor Building Standby Ventilation System).
b)
Add a new instrument item number 14 to read
" Low Range Plant Vent Stack *".
B.
Revise Technical Specification Table 4.3.7.5-1 as follows (see Attachment II) :
a)
Add a new instrument item number 14 to read
~" Low Range Plant Vent Stack #" with a Channel Check of M and Channel Calibration of R.
2.2 Equipment Qualification A.
Revise paragraph 2.C. (8) as follows (see Attachment):
a)
With the exception of the equipment for which an extension is granted by the Nuclear Regulatory Commission, the licensee shall environmentally qualify all electrical equipment according to the provisions of 10CFR50.49 prior to November-30, 1985.
3.0 REASON FOR CHANGES 3.1 Accident Monitoring Instrumentation SNPS currently has redundant low range Reactor Building Standby Ventilation System (RBSVS) noble gas radiation monitors that comply with the design and qualification.
criteria for Category 2 equipment contained in Section 1.3.2 of Regulatory Guide 1.97, Revision 2.
Redundancy for either RBSVS or plant vent stack low range noble gas radiation monitors is not required to be.in conformance with either
Regulatory Guide 1.97, Revision 2 or Revision 3.
LILCO proposed to utilize one of the two RBSVS noble gas monitors to monitor noble gas effluent in the plant vent stack, thereby providing an instrument in conformance with Category 2 requirements to monitor the last Type E variable on page 1.97-13 of Regulatory Guide 1.97, Rev. 2.
This is required because the current station vent stack noble gas radiation monitor cannot be environmentally qualified.
The sample inlet line for *PNL-021 will be rerouted from the RBSVS discharge to the station ventilation exhaust duct.
The sample discharge line will be rerouted from the Control Building roof (where it was considered as a separate ground level release for emergency planning purposes) to the station vent.
The RBSVS low range noble gas monitor in 1Dll*PNL-021 is a seismically qualified Category I monitor.
It is located in the Control Building chiller room (a non-harsh environment under all postulated accident scenarios) so that environmental qualification is not necessary.
It is supplied with emergency diesel generator power so that it will be available throughout the course of an accident.
3.2 Equipment Qualification The Code of Federal Regulations, section 50.49 (g), states that "in exceptional cases, the Commission itself may consider and grant extensions beyond November 30, 1985 for completion of environmental qualification."
The present wording of the SNPS Operating license permits no such extension.
The only purpose of this revision is to eliminate this obstacle to the granting of such extensions.
LILCO will still be required to justify each extension request on its own merits.
4.0 SIGNIFICANT HAZARDS ANALYSES 4.1 Accident Monitoring Instrumentation 01:
Does the change involve a significant increase in the probability or consequences of an accident?
A1:
These changes do not involve a significant increase in
~
the probability or consequence of an accident because:
1)
The new station vent panel is the same physical monitor which was previously designated as the low range RBSVS monitor.
It has the same lE power supply and it is seismically qualified Category I equipment.
Therefore, it cannot effect other safety-related equipment either electrically or mechanically during a seismic event.
j 2)
The new sample tubing which has been routed in the Control Building chiller room has been designed with Category I supports.
Therefore, it will not collapse or become a missile during a seismic event, thus impacting other safety-related equipment. 'The tubing running through Category II etructures has'been designed to Category I standards.
3)
The new station vent monitor does not perform any 7
automatic functions and the standby ventilation system _will continue to be monitored by one required channel.
02:
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
A2:
This change does.not create the possibility of a new or different kind of accident from any accident previously evaluated because:
1)
This monitor has not.been physically changed except that its sample inlet and discharge lines have been rerouted from the RBSVS discharge piping to the station ventilation exhaust.
The monitor has the same lE power supply and has been seismically qualified so there is no change in its impact on other plant equipment.
2)
All new piping in the Control Building has been seismically' qualified so that it cannot impact other safety-related equipment during a seismic event.
03:
Does the. change involve a significant reduction in margin of safety?
A3:
This change does not involve a significant reduction in a margin of safety because:
1)
This monitor does not perform any automatic function.
It only monitors plant effluents.
2)
Reducing the required number of RBSVS monitor channels from two to one will not reduce ~the margin of safety because only one channel is required to be operable at'any one time.
With that channel inoperable for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, Action 81 requires monitoring by an alternate method.
Therefore, having one instead of two RBSVS monitors available provides. reduced flexibility for plant operation, but does not l,
impact the ability to satisfy'this Technical Specification.
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Therefore, we conclude that operation of the Shoreham Nuclear Power Station in accordance with these proposed l
changes to the Technical Specifications, does not represent a significant hazard as defined in 10 CFR 50.92 (c) for the reasons described above.
4.2 Equipment Qualification 01:
Does the change involve a significant increase in the probability or consequences'of an accident?
A1:
The License amendment change only requests that the ability for an extension request be allowed.
1 It does not in itself change the design basis or criterion of equipment involved.
An interim justification in accordance with 10CFR50.49 and a safety evaluation in accordance with.10CFR50.59 are prepared to support extension requests.
The interim justifications are prepared in accordance with criteria in Appendix H of the i
Shoreham Equipment Qualification Report (EOR).
02:
Does the change create the possibility of a new or different kind of accident from any' accident previously evaluated?
A2:
This change does not vary'or affect any plant operating condition or parameter.
Therefore, the possibility of a new or different kind of accident from any accident previously evaluated cannot be created.
Q3:
Does the change involve a significant reduction in margin of safety?
A3:
This change provides the ability to obtain an extension to the November 30, 1985 Equipment Qualification Deadline.
Any specific extension request will be based on an accompanying interim justification.
This change does not vary any plant systems' operating conditions or margin of safety since the equipment will be justified for
~
continued plant operation.
The extension for an additional period of time does not reduce the margin of safety as originally presented in the Shoreham Environmental Qualification Report for Class 1E Equipment, whose last revision was submitted to the NRC via SNRC-917 dated June 27, 1983.
Because each item requiring extension has a specific justification prepared to ensure no loss of safety-function exists, margins of safety are maintained.
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I 5.0 TIMING OF CHANGE 5.1 Accident Monitoring Instrumentation The revised Technical Specifications should be issued as soon as they are approved.
i The physical modifications to the station may be 1
initiated but will await NRC approval of this license
(
amendment request before the physical work is complete.
5.2-Equipment Qualification The revision to the Operating License should be issued l
as soon as it is approved.
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