ML20151D138

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Proposed Tech Specs Allowing Credit to Be Taken for Radiation Monitor EMF-36 (Unit Vent Monitor) If EMF-39 (on Containment Purge Sys) Inoperable Below Mode 4 (Hot Shutdown)
ML20151D138
Person / Time
Site: Mcguire, Catawba, McGuire, 05000000
Issue date: 04/01/1988
From:
DUKE POWER CO.
To:
Shared Package
ML20151D132 List:
References
NUDOCS 8804130410
Download: ML20151D138 (22)
v • d • e


Text

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No C10nges -

INSTRUMENTATION lO O- M RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ~

LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive gaseous effluent monitoring instrumentation channels shown in TaDie 3.3-13 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded. The Alarm / Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the 00CM.

APPLICABILITY: As shown in Table 3.3-13.

ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable,
b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within'the time specified in the ACTION or, in lieu of a Licensee Event Report, explain in the next Semiannual Radioactive Effluent Release Report why this inoperability was not corrected within the time specified.
c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. l~

SURVEILLANCE REQUIREMENTS 4.3.3.9 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST operations at the frequencies shown in Table 4.3-9.

8804130410 880401 PDR ADOCK 05000369 P DCD McGUIRE - UNITS 1 and 2 3/4 3-71 Amendownt No.52(Unit 1)

Amendment No.33(Unit 2)

TABLE 3.3-13 ,-

N 4 g RAD 10 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION E MINIMUM CHANNELS

  • INSTRUMENT OPERABLE APPLICABILITY ACTION k 1. WASTE GAS HOLDUP SYSTEM t

N -

a. Noble Gas Activity Monitor - Providing ***

' H Alarm and Automatic Termination of Release I per station 35 a; (Low Range - EMF-50 or 1 EMF-36, low range)

b. Etfluent System Flow Rate Measuring Device 1 per station 36
2. WASTE GAS HOLDUP SYSTEM Explosive Gas t Monitoring System

^^ 41 -

a. Hydrogen Monitor 1 per station
b. Oxygen Monitors 2 per station 39

, 3. Condenser Evacuation System

  • 37 D Noble Gas Activity Monitor (EMF-33) 1
4. Vent System l y
  • U Noble Gas Activity Monitor 1 37
a.

(Low Range - EMF-36)

^ 40

b. Iodine Sampler 1
  • 40 1
c. Particulate Sampler

^ 36

d. Flow Rate Monitor 1 ,
  • 36 '
e. Sampler Minimum Flow Device 1 i

i 3 o 5Ox 0

L== 2ul i

I I 4

~ .

I ABil 3. 3-13 (Continued) ,

E E RAD 10ACTIVI GASIQ35 IIIlO[NI MONIIORING INSIRUMENIAll0N 5

5 MINIMUM CHANNEL 5

. INSTRUMENT OPIRABLE APPi lCABIL IIY ACil0N E 5. Containment Purge System Noble Gas Activity knitor - Providing *

- Alarm and Automatic Ierminalion of Release 1 3a (Low Range - EMI-39) o

6. Auxiliary Building Ventilation System
  • 3p Noble Gas Activity knitor (lMI-41 or 1

[Mf-36)

7. fuel Storage Area ventilation system .

Noble Gas Activity Monitor (IMf-42 or EMI-36) I 31

8. Contaminated Parts Warehouse Ventilation System ***
a. Noble Gas Activity Monitor (EMI-53) I per station 3/

w" ***

b. Flow Rate Monitor i per station 36
      • 36
c. Sampler Minimum flow Device I per station
9. Radwaste facility Ventilation System
      • 31
a. Noble Gas Activity Monitor (tMi-52) I per station Flow Rate Monitor 1 per station 36 gg b.

.. *** 36

c. Sampler Minimum flow Rate I per station 33 ~

xx 3 O

(( 10. Iquipment Staging Building Ventilation System Noble Gas Activity Monitor (LMI-59)

      • J/ FT II a. 1 r

CC

      • O 36 hh b. Ilow Rate Monitor 1

~~

c. Sampler Minimum I low (levit e I 16 d--O {

t I

7 I;BLE 3.3-13 (Continued)

TABLE NOTATION

=

At all times.

==

Ouring WASTE GAS HOLOUP SYSTEM operation.

"""Ouring gaseous effluent releases.

ACTION STATEMENTS 2:

ACTION 35 - With the number of channels OPERABLE less than requirad by the Minimum Channels OPERABLE requirement, the contents of the tank (s) may be released to the environment for up to 14 days provided that prior to initiating the release:

a. At least two independent samples of the tank's contents are analyzed, and
b. At least two technically qualifted members of the facility staff independently verify the discharge valve lineup:
1) The manual portion of the computer input for the release rate calculations performed on the computer, or
2) The entire release rate calculations if such calcula-tions are performed manually.

Otherwise, suspend release of radicactive effluents via this  ;

pathway.  ;

ACTION 36 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, efficant releases via this pathway may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ACTION 37 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samoles  !

are analyzed for gross radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. a}

ACTION 38 - - . . . .... __.,..m...,,,,,, m m,, m m. ....,,e G red by th:-

Reggg ui *-- Chan:1: Or ra:L c:wir;::nt. ' r:di+t<.ly :::p:nd PU*CI'C ;r " " ?!"O ef r:directiv: ;ff'.:nt: ef: tHe pat 4 ACTION 39 - With the number of channels OPERABLE one less than required by the Minimus Channels OPERABLE requirement, operation of this system may continue for up to 14 days. "'.t3 two channels inoperable, be in at least HOT STANOBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ACTION 40 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the effected pathway may continue for up to 30 days provided ,

samples are continuously collected with auxiliary sampling l equipment as required in Table 4.11-2. l ACTION 41 - With the number of channels OPERABLE one less than required by the Minimus Channels OPERABLE requirement, suspend oxygen ,

supply to the recomoiner.  !

Amendment No. (Unit 2) i McGUIRE - UNITS 1 and 2 3/4 3-74 Amendment No. 6 (Unit 1)

,/ 0/02 -

ACTION 38 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, immediately close all direct (unfiltered) paths to the outside environment and m:aitor EMF-36 to ensure it is not in alarm. Suspend PURGING of radioactive effluents via this pathway as soon as all direct paths are closed.

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4 PROPOSED CHANGES FOR CATAWBA

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O INSTRUMENTATION gh gG 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING FOR PLANT OPERATIONS LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels for plant operations shown in Table 3.3-6 shall be OPERABLE with their Alarm / Trip Setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

Vith a radiation monitoring channel Alarm / Trip Setpoint for plant

a. I operations exceeding the value shown in Table 3.3-6, adjust the Setpoint to w tnin the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel, i

inoperable.

b. With one or more radiation monitoring channels for plant operations -

inoperable, take the ACTION shown in Table 3.3-6.

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

l SURVEILLANCE REOUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel for plant operations shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OFERATIONAL TEST ocerations for tn tne frequencies shown in Table 4.3-3.

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IAutf 3.3-6 ,

.-1 Sa RA01All0N MONIIORING INSIRUMENIAI10N FOR PLANT OPERAIIONS f

> MINIMUN a

CilANNELS APPLICABLE ALARM /1 RIP CilANNELS g 10 1 RIP /AtARM OPERABLE MODES SE1POINI ACTION Q fDNCIl0NAL UNIT w

" 1. Containment e- ^^^ 30 1 All N a. Containment Atmosphere - liigh 1 Gaseous Radioactivity (Low Range - EMF-39)

b. Reactor C'>olant System Leakage Detection
1) Pari.iculite Radioactivity I 1, 2, 3, 4 N.A. 33 (Low Range - EMF-38) N.A.

w s

  • 2) Gaseous Radioactivity 33 1, 2, 3, 4 H.A. .

(Low Range - emf-39) N.A. I T

~E

2. Iuel Storage Pool Areas
a. liiglt Gaseous Radioactivity 1

^^ $ 1.7x10 4 pCi/ml 34 (Ww Range - Ehf-42) I

b. Criticality-Radiatiori level (fuel Bridge - Low Range -
  • 32 1 1 $ 15 mR/h 1[MF-IS, 2 EMF-4)
3. Control Room 1/ intake 2 (1/in- All 5 1.7x10 4 pCi/mi 31 S{

s hK Air intake-Radiation Level - take) liigh Gaseous Radioactivity O (Low Range - LMF-43 A & B) D

$ 1.7x10 4 pCi/s.1 35 1 1, 2, 3, 4 ,

Auxiliary Building Ventilation 1 4.

liigh Gaseous Radioactivity - g3 (Low Range - emf-41) 8 1 lx10 3 pCi/ml 5

$ Component Cooling Water fvstem I 1 All

.LMf-4b A&ll)

TABLE 3.3-6 (Continuedl TABLE NOTATIONS f

j

  • With fuel in the fuel storage pool areas.
    • With irradiated fuel in the fuel storage pool areas. '

When venting or purging from containment to the atmosphere, the trip set-point shall not exceed the equivalent limits of Specification 3.11.2.1 in accordance with the methodology and parameters in the 00CM. When not vent- ])

ing or purging in Modes 5 or 6, the alars setpoint concentration (pCi/sl) (2 shall be such that the actual submersion dose rate would not exceed SsR/hr without alare. When not venting or purging in Modes 1 through 4 the alars h )

setpoint shall be no more than 3 tipo the containment atmosphere activity ( )

as indicated by the radiation monitor. ,

) ;

ACTION STATEMENTS l ACTION 30 - With the number of channels OPERABLE less than required by )

the Minimum Channels OPERABLE requirement, immediately i

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"J"'I.'C f r: i:::t' .i; r.i; an.%e,. 1 Close oil dire c.7 (un%eredh;;pa;f rhs to th.

f'.:nt: o u r s i d e, e nv eren ment- ond assure.. EMF -36 #S OPERABLE, Otherwse, suspwd Pug c4 g. op cad,eeer,ye e(plu'ents Vlo this p a thwoy.

ACTION 31 - With the number of operable channels one less than the Minimum .;

Channels OPERA 8LE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the affected Control Room Ventilation System intake from outside air with flow through the HEPA filters and carbon adsorters. -

ACTION 32 - With less than the Minimus Channels OPERABLE requirement, opsra-tion say continue for up to 30 days provided an appropriate portah'a continuous monitor with the same Alars Setpoint is provided in tt:e fuel storage pool area. Restore the inoperable monitors to OPERA 8LE status within 30 days or suspend all operations involving fuel movement in the fuel building.

ACTION 33 - Must satisfy the ACTION requirement for Specification 3.4.6.1.

ACTION 34 - With the number of OPERABLE channels less than the Minimum Channels OPERA 8LE requirseent, operation may continue provided the Fuel Handling Vantilation Exhaust System is operating and discharging through the HEPA filters and carbon adsorbers.

Otherwise, suspend all operations involving fuel movement in the fuel building.

ACTION 35 - With the number of OPERABLE channels less than the Minimum Channels OPERA 8LE requirement, operation say continue provided the Auxiliary Building Filtered Exhaust System is operating and discharging through the HEPA filter and carbou adsorbers.

ACTION 36 - With the %mber of OPERA 8LE channels less than the Minimum Channels OPERA 8LE requirement, operation say continue for up to 30 days provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab seeples are collected and analyzed for radioactivity (gross gaema) at a lower limit of detection of no more than 10 7 pC'/m1.

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CATAWBA - UNITS 1 & 2 3/4 3-53 Amendment No. Unit 1)

Amendment Nod Unit 2)

1 N o C b u LC r C/ --

INSTRUMENTATION UM[

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION l

LIMITING CONDITION FOR OPERATION 3.3.3.11 The radicactive gaseous affluent monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specifications 3.11.2.1 and 3.11.2.5 are not e .ceeded.

The Alarm / Trip Setpoints of these channels meeting Specification 3.11.2.1 shall be determined and adjusted in accordance with the methodology and parameters in the 00CM.

APDLICABILITY: As shown in Table 3.3-13.

I ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel -

Alarm / Trip Setpoint less cor.servative than required by the acove specification, immediately suspena tne release of radioactive ,

gaseous effluents monitored by the affected channel, or declare the channel inoperable.

l

b. With less than the minimum number of radioactive gaseous effluent I monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within the ti e specified in the ACTION, or explain in the next Semiannual Radioactive Effluent Release Report pursuant to Specification 6.9.1.7 why this inoperability was not corrected within the time specified.

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c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

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5URVEIL'..ANCE REQUIREMENTS 4.3.3.11 Each radioactive gaseous effluent monitoring instrumentation channel snail be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST operations the frequencies shown in Table 4.3-9.

CATAW8A - UNITS 1 & 2 3/4 3-85 l

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lABLE 3.3-13 ,

9

" RADIDACIIVE GASIGUS EffLUENI HONIIORING INS 1RUMENIAIION 2-HINIMUM CilANNELS ACTION OPERABLE APPLICABILITY E INSIRUMENI

1. WASlE GAS Il0LDUP SYSIEN e* a. Noble Gas Activity Monitor -

" Providing Alarm and Automatic

  • 4S lermination of Release (Low I per station Range - emf-50)

Effluent System flow Rate

  • 46
b. 1 per station Measuring Device
2. WASIE GA5 ll0LDUP SYSILM Explosive Gas w

Mar.itoring System

) -

1/ train per station

    • 51 w
a. Ilydrogen Monitors g 2/ train per station 8^ 49
b. Oxygen Monitors 1,2,3,4 47 1
3. Condenser Evacuation System Noble Gas Activity Monitor (low Range - emf-33)
4. Vent System
  • 47 I
a. Noble Gas Activity Monitor 1

g l

' (Low Range - EMF-36) hh g

  • 50 .

1

b. lodine Sampler ([Mf-37)
  • 50
c. Particulate Sampler ([Mf-35) 1 \O O M
  • 46 4 1  % D
d. Ilow Rate Monitor ^ 46 (b'N I
e. Sampler flow Rate Monitor b

]

4

IABLE 3.3-13 (Continued) _

. t 3 RAD 10ACllVE GASEQUS EFFLUENI HONITORING INSIRUMENIAIlON y

n-MINIMUM CilANNELS APPLICABILITY ACTION DPERABLE E INSlHUMENI Q
5. Containment Purge System e
  • Noble Gas Activity Monitor - Providing *** 48 1

" Alarm and Automatic Termination of Release (Low Range - EHF-39)

6. Containment Air Release and Addition System
  • 45 1

Noble Gas Activity Monitor - Providing Alarm (Low Range - EMF-39)

R.

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l TABLE 3.3-13 (Continued)

TABLE NOTATIONS

  • At all times except when the isolation valve is closed and locked.
    • Ouring WASTE GAS HOLDUP SYSTEM operation.
      • At all times.

ACTION STATEMENTS ACTION 45 - With the number of channels OPERABLE less than required by the Minimus Chinnels OPERABLE requirement, the contents of the tank (s) may be released to the environment for up to 14 days provided that orior to initiating the release either:

a. Vent system nobl6 gas activity monitor providing alarm and automatic termination of release (Low Range - EMF-36) has at least one channel OPERABLE, or
b. At least two independent samples of the tank's contents are analyzed, and at least two technically?

qualified members of the facility staff independently verify:

1. The discharge valve lineup, and '
2. The manual portion of the computer input for the f release rate calculations performed on the l computer, or the entire release rate calcula-tions if such calculations are performed manually.

Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 46 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided the flaw rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ACTION 47 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, affluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

ACTION 48 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, immediately

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"L'RCIMC
,f r
di;;;tiV: ;ffh;nt: .ia t..i; ;; G ;y.

Close oil dire c.T (un6hered) parhs to rha_ c u r s i d e.

e nv iro n men t-ond assure.. EMF -36 as OPERABLE, Otherwise, suspend Pua ca N s of rad iocu in eMMents Vto this pa thway. ,

l CATAW8A - UNITS 1 & 2 3/4 3-88

\

NO Conf i

TABLE 3.3-13 (Continued)

Y4IS fQ} &  ;

TABLE NOTATIONS j

ACTION 49 -

With the number of channels OPERABLE one less than required i by the Minimus Channels OPERABLE requirement, operation of this system may continue provided grab samples With are taken both  ;

and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. l channels inoperable, operation may continue provided grab

(

samples are taken and analyzed at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> '

during degassing operations and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during other operations.

ACTION 50 -

With the number of channels OPERABLE 1ess than required by 1 the Minimum Channels OPERABLE requirement, effluent releases via the affecte:1 pathway may continue for up to 30 days providtd samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.

ACTION 51 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, suspend oxygin supply to the recombiner.

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CATAWBA - UNITS 1 & 2 3/4 3-89

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ATTACHMENT 3 JUSTIFICATION AND SAFETY ANALYSIS FOR MCGUIRE CHANGES f

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, - - - ,. - , , - - n ---- .-, - -- -- - - ~ ----

e Justification and Safety Analysis The proposed changes to the McGuire Nuclear Station Technical Specifications seek to clarify the operability requirements of the Containment Purge System low range noble gas activity monitor, EMF-39. The present Specifications require the monitors to be operable providing alarm and automatic termination of release at all times. An event at McGuire in 1987 (reference LER 370/87-06 dated June 29, 1987) demonstrated that this needs to be reconsidered.

The event involved the loss of flow to the monitor while the unit (McGuire Unit 2) was in no mode status (no fuel in the reactor or containment buildings) ,

with the equipment hatch open. Briefly, when flow to the monitor was lost, the equipment hatch could not be closed due to a problem with the equipment hatch gasket. Operators made the decision to continue containment purge to prevent any unfiltered release to the environment through the equipment hatch. When it was determined that no radiological hazard existed in containment, the purge system was secured in accordance with Technical Specifications.  ;

The proposed changes to the McGuire Technical Specifications seek to change the required compensatory actions (ACTION c'atements) in the event EMF-39 is inoperable as to take credit for the unit vent noble gas monitor, EMF-36.

If EMF-39 detects high radiation, it will send a signal to the solid state pro-tection system (energizing relay K615) which will isolate the containment purge (VP) system. The SSPS will also isolate Vp on a safety injection (phase "A" containment isolation) signal, independent of the status of EMF-39.

While the SSPS may be removed from service below Mode 4, temporary wiring may be installed to maintain power to relay K615. While this maintains the automatic j isolation capability of the EMF under these circumstances, it does not take into account the possible inoperability of the monitor itself, as occurred in the referenced Licensee Event Report.

b The automatic isolation capability of the containment purge system is also required by Specification 3.3.2, Table 3.3-3, Item 3.C for Modes 1,2,3, and 4.

While this involves redundant requirements in the Technical Specifications, the point to be noted here is that the revised action statement to take credit for EMF-36 is preempted by the more conservative action statement in Modes 1-4 (requiring closure of the containment purge supply and exhaust valves) presently in the Technical Specifications. The proposed changes, therefore will have no effect in Modes 1,2,3, and 4. In any case, McGuire does not operate the containment purge system in Modes 1-4.

The proposed change will therefore only affect operation in Modes 5, 6, and no mode status. The accidents considered with the reactor in these modes are the boron dilution accident and the fuel handling accident.

In Mode 5, Cold Shutdown, a fuel handling accident in containment is not possible. A boron dilution incident in Mode 5 is possible, however is highly improbable. As discussed in FSAR Section 15.4.6, conscious operator action is required to initiate boron dilution and sufficient time is available for the operators to terminate the dilution and reborate the system prior to criticality.

In Mode 6, refueling, the primary accident of concern is the fuel handling accident. While EMF-39 may be inoperable during refueling and thus unavailable for automatic isolation of containment purge, the unit vent monitor, EMF-36 will p.,, , ,w-w w-w i:: -------.--a -,--+rw y, -- e,r...-e. _ -- v-- ,, ...,m..e-. . , - - , . m - - m-,.,,, - . . ,, . _- rn.,,-e

be available to alert operators (by annunciator alarm) to isolate the release.

Additionally, Specification 3.9-5 requires direct communication between refueling personnel and the control room.

A boron dilution event may occur during refueling, however, again conscious operator action is required to initiate dilution. This is discussed in the McGuire FSAR, Section 15.4.5. Should a boron dilution be initiated, the operator would have nearly an hour to recognize the high count rate (from the source range detectors) and terminate the dilution. This assures that no criticality can occur during refueling which, by ruling out fuel damage as a release source, precludes any large releases of fission products.

The proposed revised Action statement for an inoperable monitor would take credit for the unit vent noble gas monitor, EMF-36. Specification 3.3.2 requires monitor EMF-39 and its automatic isolation function to be Operable in Modes 1,2,3 and 4 with the Action statement requiring the purge supply and exhaust valves to be maintained closed should the automatic isolation capability be inoperable. As the existing Action 17 of Table 3.3-3 is more conservative than the proposed Action 38 of Table 3.3-13, it (the existing Action 17) would preempt the propased Action in Modes 1,2,3, and 4; therefore the only effect is in Modes 5 and 6 (when no fuel is being moved insido containment), and when the unit is in "no mode" status.

The accidents considered in Modes 5 and 6 are the boron dilution accident and the fuel handling accident. As previously discussed, the analyses for these accidents are unaffected by the operability of EMF-39, and no credit is taken for the termination of a release due to EMF-39. Therefore, no margins of safety as presented in the FSAR are affected.

Analysis of Significant Hazards Considerations purr.uant to 10CFR 50.91, provided is an analysis conforming to the standards of 10CFR 50.92 to conclude that the proposed changes to the McGuire and Nuclear l Station Technical Specifications do not involve any significant hazards considerations.

(1) The proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The accidents that have been evaluated for Modes 5 and 6 (and "no mode" status) are the boron dilution accident and the fuel handling accident, the function of the monitors is to alert operators to a radioactive release and quantify and terminate the release. The monitors do not affect any accident initiating scenarios. Conscious operator action is i I

required to initiate boron dilution and sufficient time exists to terminate the event before a criticality occurs; no releases occur for this sequence. The fuel handling accident during refueling may result in an offsite release if EMF-39 is not available to automatically terminate the release; however, the analysis of the fuel handling accident as presented in the McGuire FSAR, Section 15.7.4.1 takes no credit for release reduction due to containment isolation. Therefore, the consequences of the accident as analyzed are unaffected by the operability of EMF-39, and in fact would be less than FSAR doses if the purge system is isolated by EMF-39 or manually in response to EMF-36.

_ _. . . . . _ _ _ __ _ . - ~ _ __ ~. . _ . . __ . . - _ -

3 (2) The proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not involve any hardware changes as to create l any new accident scenarios. The active function of the monitors are merely to provide alarm, and in the case of EMF-39, isolate the con-tainment purge system (though not assumed in the safety analysis).

There.aro no equipment or system interfaces (or changes thereto) that may create a new accident sequence.

(3) The proposed changes would not involve a significant reduction in a margin of safety.

  • The proposed changes will not affect any margins of safety as stated in the FSAR. The only potentially affected safety function is the automatic isolation function of EMF-39. If EMF-39 is disabled during a' .

fuel handling accident, the operators may manually isolate containment purge in response to EMF-36 alarming or communications from  !

containment. In any event, the FSAR analysis assumes no containment isolation occurs to red' ice offsite doses. The offsite doses for the fuel handling accident, as presented in McGuire FSAR Table 15.0.11-1 and associated margins to 10CFR 100 limits, are unaffected.

i Based upon the preceding analyses, Duke Power concludes that the proposed changes -

to the McGuire Nuclear Station Technical Specifications 30 not involve any significant hazards considerations.

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ATTACHMENT 4 JUSTIFICATION AND SAFETY ANALYSIS FOR CATAWBA CHANGES 1

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Justification and Safety Analysis 1The proposed changes to the Catawba Nuclear Station Technical Specifications seek to clarify the operability requirements of the Containment Purge System low range noble gas activity monitor, EMF-39. The present Specifications require the monitors to be operable providing alarm and automatic termination of release at all times. An earlier event at McGuire (reference LER 370/87-06 dated June 29, 1987) demonstrated that this needs to be reconsidered.

The event involved the loss of flow to the monitor while the unit (McGuire Unit 2) was in no mode status (no fuel in the reactor or containment buildings) with the equipment hatch open. Briefly, when flow to the monitor was lost, the equipment hatch could not be closed due to a problem with the equipment hatch gasket. Operators made the decision to continue containment purge to prevent any unfiltered release to the environment '.hrough the equipment hatch. When it was determined that no radiological h:aard existed in containment, the purge system was secured in accordance with Technical Specifications.

The proposed changes to the Catawba Technical Specifications seek to change the required compensatory actions (ACTION statements) in the event EMF-39 is inoperable as to take credit for the unit vent noble gas monitor, EMF-36.

If EMF-39 detects high radiation, it will send a signal to the solid state protection system (energizing relay K615) which will isolate the containment (

purge (Vp) system. The SSPS will also isolate VP on a safety injection (phase "A" containment isolation) signal, independent of the status of EMF-39.

While the SSPS may be removed from service below Mode 4, temporary wiring may be installed to maintain power to relay K615. While this maintains the automatic isolation capability of the EMF under these circumstances, it does not take into account the possible inoperability of the monitor itself, as occurred in the referenced Licensee Event Report i

The automatic isolation capability of the containment purge system is also required by Specification 3.3.2, Table 3.3-3, Item 3.C for Modes 1,2,3, and 4.

While this involves redundant requirements in the Technical Specifications, the point to be noted here is that the revised action statement to take credit for EMF-36 is preempted by the more conservative action statement in Modes 1-4 (requiring closure of the containment purge supply and exhaust valves) presently in the Technical Specifications. The proposed changes, therefore will have no effect in Modes 1,2,3, and 4.

l The proposed change will therefore only affect operation in Modos 5, 6, and no mode status. The accidents considered with the reactor in these modes are the boron dilution accident and the fuel handling accident.

In Mode 5, Cold shutdown, a fuel handling accident in containment is not possible. A boron dilution incident in Mode 5 is possible, however is highly improbable. As discussed in FSAR Section 15.4.6, conscious operator action is required to initiate boron dilution and sufficient time is available for the operators to terminate the dilution and reborate the system prior to criticality.

l In Mode 6, refueling, the primary accident of concern is the fuel handling accident. While EMF-39 may be inoperable during refueling and thus unavailable for automatic isolation of containment purge, the unit vont monitor, EMF-36, will be available for automatic isolation of releases from the unit vent. In any

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case, the analysis and dose assessment in the Catawba FSAR, Section 15.7.4.2.2 does not take credit for isolating the release and doses are within 10CFR 100 limits, thus no margins of safety are affected.

A boron dilution event may occur during refueling, however, again conscious operator action is required to initiate dilution. This is discussed in the Catawba FSAR, Section 15.4.6. Should a boron dilution be initiated, the operator I would have nearly an hour to recognize the high count rate (from the source range detectors) and terminate the dilution.

Additional assurance exists at Catawba due to the automatic actuation of the Boron Dilution Mitigation System. The details of this system and its actuation, logic and alignments are discussed in the Catawba FSAR, Section 15.4.6. This assures that no criticality can occur in Modes 5 and 6 which, by ruling out fuel damage as a release source, precludes any large releases of fission products.

The proposed revi. sed Action statement for an inoperable monitor would take credit for the unit vent noble gas monitor, EMF-36. Specification 3.3.2 requires j monitor EMF-39 and its automatic isolation function to be operable in Modes 1,2,3 I and 4 with the Action statement requiring the purge supply and r haust valves to be maintained closed should the automatic isolation capability be inoperable. As the existing Action 17 of Table 3.3-3 is more conservative than the proposed Action 48 for Catawba of Table 3.3-13, it (the existing Action 17) would preempt the proposed Action in Modes 1,2,3, and 4; therefore the only effect is in Modes 5 and 6, and when the unit is in "no mode" status.

The proposed change to Table 3.3-6 (Specification 3.3.3.1) Action 30 is to ensure consistency of required compensatory measures for an inoperable piece of equipment. While this involves multiple specifications governing a single monitor, deletion from Specification 3.3.1 is not practical due to specification of the trip setpoint, nor is deletion from Specification 3.3.11 practical due to additional surveillance requirements.

The accidents considered in Modes 5 and 6 are the boron dilution accident and the fuel handling accident. As previously discussed, the analyses for these accidents are unaffected by the operability of EMF-39, and no credit is taken for the termination of a release due to EMF-39 or EMF-36. Therefore, no margins of safety as presented in the FSAR are affected.

Analysis of Significant Hazards Considerations pursuant to 10CFR 50.91, provided is an analysis conforming to the standards of 10CFR 50.92 to conclude that the proposed changes to the Catawba Nuclear Station Technical Specifications do not involve any significant hazards considerations.

(1) The proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The accidents that have been evaluated for Modes 5 and 6 (and "no mode" status) are the boron dilution accident and the fuel handling accident.

The function of the monitors is to alert operators to a radioactive release and quantify and terminate the release. The monitors do not affect any accident initiating scenarios. Conscious operator action is required to initiate boron dilution. Sufficient time exists for automatic actuation of the boron dilution mitigation system to

terminate the event before a criticality occurs; thus no releases occur-for this sequence. Tha fuel handling accident during refueling may result in an offsite release if EMF-39 is not available to automatically tenminate the release; however, EMF-36 will be available to terminate the release, and the analysis of the fuel handling accident as presented in the Catawba FSAR, Section 15.7.4.2.2, takes no credit for release reduction due to containment isolation. Therefore, the consequences of the accident.as_ analyzed are unaffected by the operability of EMF-39, and in fact would be less than FSAR doses if the purge system is isolated by EMF-39 or in response to EMF-36.

(2) The proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not involve any hardware changes as to create any new accident scenarios. The active function of the monitors are merely to provide alarm, and in the case of EMF-39, isolate the containment purge system (though not assumed in the safety analysis).

There are no equipment or system interfaces (or changes thereto) that may create a new accident sequence.

(3) The proposed changes would not involve a significant reduction in a margin cf safety.

The proposed changes will not affect anv margins of safety as stated in the FSAR. The only potentially affected safety function is the automatic isolation function of EMF-39. If EMF-39 is disabled during a fuel handling accident, the operators may manually isolate containment purge in response to EMF-36 alarming or communications from containment. In any event, the FSAR analysis assumes no containment isolation occurs to reduce offsite doses. The offsite doses for the fuel handling accident, as presented in Catawba FSAR Table 15.0.12-1 and associated margins to 10CFR 100 limits, are unaffected.

Based upon the preceding analyses, Duke dcNer concludes that the proposed changes to the Catawba Nuclear Station Technical Specifications do not involve any significant hazards considerations.

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