ML20206P266
| ML20206P266 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/30/1998 |
| From: | NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML20206P258 | List: |
| References | |
| NUDOCS 9901110063 | |
| Download: ML20206P266 (14) | |
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ATTACHMENT A l
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NIAGARA MOHAWK POWER CORPORATION i LICENSE NO. DPR-63 DOCKET NO. 50 220 Proposed Chcnaes to the Current Technical Snecifications (TSs) l t l Replace the existing pages 290,293, and 305 with the attached corresponding revised pages. The revised replacement pages have been retyped in their entirety, incorporating the changes, and include marginal markings (revision bars) to indicate the changes.
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f 9901110063 981230 -
TABLE 3.6.14-2 (cont'd)
RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION - .;
Minimum instrument Channels Operable Anolicability Action.
- 3. '
Condenser Air Ejector Radio-activity Monitor (Recombiner discharge or air ejector discharge)
- ' (g)
- a. Noble Gas Activity 1
- b. Offgas System Flow Rate 1 -(c)
Measuring Devices
- c. Sampler Flow Rate 1 (c)
Measuring Devices
- 4. Emergency Condenser System
- a. Noble Gas Activity Monitor 1 per vent (h)
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- During operation of the main condenser air ejector
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- During power operating conditions and whenever the reactor coolant temperature is greater than 212*F except for hydrostatic testing with the reactor not critical.
t AMENDMENT NO. //d 290
NOTES FOR TABLE 4.6.14-2 .
(2) At all times. }
(b) The channel' calibration shall be performed using one or more of the reference standards certified by the National Bureau of
. Standards, standards that are traceable to the National Bureau of Standards or using actual samples of gaseous effluent ,that have been analyzed on a system that has' been calibrated with National Bureau of Standards traceable sources. .These standards shall ~
permit calibrating the system over its intended range of energy and measurement.
(c) The channel function test shall demonstrate that control room alarm annunciation occurs if either of the following conditions exist:
- 1) instrument indicates measured levels above the Hi or Hi Hi alarm setpoint.
- 2) Instrument indicates a downscale failure.
The channel function test shall also demonstrate that automatic isolation of this pathway occurs if either of the following conditions exist:
' Instruments indicate two channels above Hi Hi alarm setpoint.
1)
- 2) Instruments indicate one channel above Hi Hi alarm setpoint and one channel downscale.
(d) During main condenser offgas treatment system operation.
(s) The channel calibration shall include the use of standard gas samples containing a nominal:
(f) During operation of the main condenser air ejector.
(g) The channel test shall produce upscale and downscale annunciation.
(h) During power operating conditions and whenever the reactor coolant temperature is greater than 212*F except for hydrostatic testing with the reactor not critical.
AMENDMENT NO. /dd 293 1
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UMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT -
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- c. . Main Condenser c. Main Condenser l The gross radioactivity (beta and/or gamma) rate The radioactivity rate of noble gases at the
- of noble gases measured at the recombiner recombiner discharge shall be continuously 4
discharge shall be limited to less than or equal to motiitored in accordance with Table 3.6.14-2. t 500,000 pCi/sec. This limit can be raised to 1 Ci/sec. for a period not to exceed 60 days The gross radioactivity (beta and/or gamma) rate provided the offgas treatment system is in of noble gases from the recombiner discharge operation. shall be determined to be within the limits of i Specification 3.6.15 at the following frequencies i With the gross radioactivity (beta and/or gammal by performing an isotopic analysis of a represent- ;
rate of noble gases at the recombiner discharge ative sample of gases taken at the recombiner exceeding the above limits, restore the gross discharge:
radioactivity rate to within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least Hot Shutdown within the Monthly:
next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following an increase on the
- d. Uranium Fuel Cycle recombiner discharge monitor of greater than 50%, factoring out increases due to changes The annual (calendar year) dose or dose in thermal power level and dilution flow commitment to any member of the public due to changes. j releases of radioactivity and to radiation from I uranium fuel cycle sources shall be limited to less d. Uranium Fuel Cycle i than or equal to 25 mrems to the total body or any organ, except the thyroid, which shall be Cumulative dose contributions from liquid and j
. limited to less than or equal to 75 mrems. gaseous effluents shall be determined in accordance with Specifications 4.6.15.a.(2),
4.6.15.b.(2) and 4.6.15.b.(3) and in accordance l with the methodology and parameters in the i
Offsite Dose Calculation Manual. i i
i AMENDMENT NO. /dd 305
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!, ATTACHMENT B NIAGARA MOHAWK POWER CORPORATION LICENSE NO. DPR-63 DOCKET NO. 50-220 l
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Suonortina Information and No Sionificant Hazards Consideration Analvsis 1 INTRODUCTION The proposed changes to the Nine Mile Point Unit 1 (NMP1) Technical Specifications (TSs) contained herein represent revisions to NMP1 TS Sections 3.6.14 and 4.6.14, " Radioactive Effluent Instrumentation," and Section 4.6.15, " Radioactive Effluents." No changes to the l TS Bases are required. '
The NMP1 Emergency Cooling System (ECS) is a standby system that is designed to remove fission product decay heat, without the loss of reactor water, following a reactor scram when the main condenser is not available as a heat sink or in the event of a loss of reactor feedwater. The ECS consists of two independent loops, each with two Emergency 1 Condensers. The system operates by natural circulation, with each loop drawing steam from the reactor vessel and transferring it to the tubes of the Emergency Condensers via a !
steam supply line. The shell side of each pair of Emergency Condensers contains a normal l supply of water which will boil, thereby removing heat from the reactor steam (in the tubes) and condensing it to the liquid state for retum to the reactor vessel. In the standby condition, the steam inlet isolation valves are normally open so that the Emergency Condenser tube bundles are continuously at reactor pressure. The ECS is placed into cperation by opening the normally closed condensate return isolation valves (one valve per loop).
Automatic operation of the ECS is initiated by high reactor pressure sustained for a preset time period. To assist in reactor depressurization for small breaks, the ECS is also automatically initiated on low-low reactor water level, sustained for a preset time period.
The preset time delay is provided to prevent unnecessary actuation of the ECS during anticipated transients, such as turbine trips, when the main condenser is still available.
The ECS is credited for events that could result in loss of feedwater or reactor isolation from the primary heat sink. In addition, the ECS aids the Core Spray System and Automatic Depressurization System in providing effective core cooling following non-limiting small breaks. The ECS is also relied upon as the principal means to bring the plant to a hot shutdown condition under such unanticipated operational occurrences as a Station Blackout or a 10 CFR 50 Appendix R fire event.
The shell side of each Emergency Condenser is vented to the atmos. ,re and the common
.- atmospheric vent line for each pair of Emergency Condensers is m tided with two Noble Gas Activity Monitor channels. These monitors provide annunciation in the Control Room of high radiation resulting from tube bundle leaks in the Emergency Condensers. The ECS
! is described in Section V-E of the NMP1 Updated Final Safety Analysis Report (UFSAR) and the associated Noble Gas Activity Monitors are described in Section Vill-C 3.1.1 of the l
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l l. Chances to TSs 3.6.14 and 4.6.14 TS Table 3.6.14 2 currently requires at least one channel of the Emergency Condenser Vent Noble Gas Activity Monitors (Instrument 4.a) to be operable when the reactor is in l the power operating condition. Similarly, TS Table 4.6.14-2 requires the daily sensor j check surveillance for the Noble Gas Activity Monitor (Instrument 4.a) to be performed i when the reactor is in the power operating condition. These requirements were
! established to provide assurance that the radiological dose rates for the gaseous effluents
( specified in Limiting Condition for Operation (LCO) 3.6.15.b.1 are not exceeded. To
! provide this assurance, at least one channel of the Noble Gas Activity Monitor for each l ECS loop common atmospheric vent should be operable during the conditions specified in LCO 3.1.3.a. TS LCO 3.1.3.a establishes the operability conditions for the ECS loops, including their respective Emergency Condensers. Specifically, the LCO requires both ECS loops (referred to in the LCO as "both emergency cooling systems") to be operable during l
reactor power operation and whenever the reactor coolant temperature is greater than 212 F, except for hydrostatic testing with the reactor not critical.
Niagara Mohawk Power Corporation (NMPC) proposes to make the application of the Emergency Condenser Vent Noble Gas Activity Monitor channel operability requirement (TS l Table 3.6.14-2.4.a) and the application of the daily sensor check Surveillance Requirement (SR) (TS Table 4.6.14-2.4.a) consistent with the conditions specified in LCO 3.1.3.a for l operability of the ECS loops. Specifically, these changes will extend the operability and
! daily sensor check surveillance requirements for the Emergency Condensor Vent Noble Gas Activity Monitors to include, in addition to power operations, the condition when reactor l coolant temperature is greater than 212oF, except for hydrostatic testing.
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- 11. Chanae to TS 4.6.15 l
TS SR 4.6.15.d currently requires the cumulative dose contributions from liquid and gaseous effluents for the Uranium Fuel Cycle to be determined in accordance with TS SRs 4.6.15.a.(2), 4.6.15.b.(2), and 4.6.16.b.(3). However, there is currently no TS SR 4.6.16.b.(3). TS SR 4.6.15.b.(3), which applies to the cumulative dose contributions for iodine-131, iodine-133, tritium, and radionuclides in particulate form with half lives greater than eight days, is the correct reference instead of SR 4.6.16.b.(3). This conclusion is based on TS Amendment No. 66, which included the correct reference. The numbering error occurred during the preparation of the July 31,1987 Radiological Effluent Technical Specifications (RETS) amendment application. This apparent clerical error was inadvertently carried over to TS Amendment No. 94, which was approved on February 8, 1988. NMPC proposes to correct SR 4.6.15.d by incorponting the correct reference.
EVALUATION Currently, at least one channel of the Emergency Condenser Vent Noble Gas Activity Monitors is required to be operable and the daily sensor check surveillance is required to be performed when the reactor is in the power operating condition. 10 CFR 50 Appendix A, General Design Criterion (GDC) 64, " Monitoring Radioactivity Releases," requires monitoring of effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents. Analyses credit the ECS for event sequences and accidents that can l 2 of 5 l
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I j be postulated for power operating conditions, as well as for conditions when the reactor coolant temperature is greater than 212 F, except for bydrostatic testing with the reactor
- not critical. NMPC proposes to modify the Footnote for TS Table 3.6.14 2 and Note for j- Table 4.6.14-2 to make the conditions for Emergency Condenser Vent Noble Gas Activity i Monitor operability and daily sensor check surveillance performance consistent with the more restrictive conditions for ECS operability. These changes satisfy the intent of GDC
- 64 by requiring the Emergency Condenser Vent Noble Gas Activity Monitors to be operable during the conditions specified in LCO 3.1.3.a for operability of the ECS (i.e., during power
- operating conditions and when reactor coolant temperature is greater than 212oF except i for hydrostatic testing with the reactor not critical). The proposed changes to TS Tables 3.6.14-2 and 4.6.14-2 will provide the appropriate operability and surveillance applicability j requirements to assure that the radiological dose and dose rates for gaseous effluents will
- not exceed the limits for noble gases specified in 10 CFR 50 Appendix 1,10 CFR 20, and j LCO 3.6.15.b.1, as applicable.
The clerical error in TS SR 4.6.15.d did not affect the methodology or parameters established in the Offsite Dose Calculation Manual (ODCM), nor did it affect the associated implementing procedures for calculating the cumulative dose contributions from the iodine- 1 131, iodine-133, tritium, ar'd particulate sources. Thus, the clerical error had no impact on the plant and the proposed correction provides continued assurance that the cumulative dose contributions from Uranium Fuel Cycle sources, including direct radiation and allliquid and gaseous pathways, are maintained within the limits of LCO 3.6.15.d and 40 CFR 190.
CONCLUSIONS The proposed changes to TS Tables 3.6.14-2 and 4.6.14 2 satisfy the intent of 10 CFR 50 Appendix A, GDC 64, and provide continued assurance that the radiological dose rates for gaseous effluents will not exceed the limits for noble gases specified in 10 CFR 50 Appendix 1,10 CFR 20, and LCO 3.6.15.b;1.
The proposed change to TS SR 4.6.15.d is administrative in nature and has no impact on the plant or safety significance.
The Proposed changes will not degrade the quality or performance of the ECS or affect its capability to mitigate the consequences of an accident that results in a loss of feedwater or reactor isolation from the primary heat sink. The proposed changes also will not affect the capability of the ECS to aid the Core Spray System and Automatic Depressurization System in providing effective core cooling following non-limiting small breaks. In addition, the proposed changes provide continued assurance that plant operation will be conducted in compliance with NRC regulations applicable to radiological effluent releases offsite, it is, therefore, concluded that there is reasonable assurance that the health and safety of the public will not be adversely affected by operation of NMP1 in the proposed manner.
NO SlONIFICANT HAZARDS CONSIDERATION ANALYSIS According to 10 CFR 50.91, at the time a licensee requests an amendment to its operating license, the licensee must provide to the NRC its analysis concerning the issue of no significant hazards consideration using the standards in 10 CFR 50.92. According to 10CFR 50.92(c), a proposed amendment to an operating license involves no significant 3 of 5
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N i hazards considerations if operation of the facility in accordance with the proposed
- , amendm,ent would not:
} 1. Involve a significant increase in the probability or consequences of an j- accident previously evaluated; or
! 2. Create the possibility of a new or different kind of accident from any
- accident previously evaluated; or i
- 3. Involve a significant reduction in a margin of safety.
- Niagara Mohawk Power Corporation (NMPC) has evaluated this proposed amendment pursuant to 10 CFR 50.91 and has determined that it involves no significant hazards 1
considerations.
The following analyses have been performed:
The operation of Nine Mile Point Unit 1. in accordance with the orooosed amendment, will not involve a sianificant increase in the orobability or consecuences of an accident oraviousiv evaluated.
The proposed changes extend the application of operability and daily sensor check surveillance requirements for the Emergency Condenser Vent Noble Gas Activity Monitors to include, in addition to power operations, the condition when reactor coolant temperature is greater than 212 F, except for hydrostatic testing.- These changes will make the conditions for Emergency Condenser Vent Noble Gas Activity Monitor operability and daily sensor check surveillance performance consistent with the conditions for ECS operability as indicated in LCO 3.1.3.a.
The proposed changes to the Emergency Condenser Vent Noble Gas Activity Monitor operability and daily sensor check surveillance requirements will continue to provide assurance that the intent of the effluent monitoring requirements of 10 CFR 50 Appendix A, GDC 64,is satisfied and the radiological effluents are maintained within the dose and dose rate limits specified in 10 CFR 50 Appendix 1,10 CFR 20, and the RETS. The proposed changes will not affect the capability of the ECS to mitigate the consequences of an accident that results in a loss of feedwater or reactor isolation from the primary heat sink and aid the Core Spray System and Automatic Depressurization System in providing effective core cooling following non-limiting small breaks.
. The proposed changes also correct a clerical error in the Uranium Fuel Cycle effluent monitoring SR. The proposed correction simply restores the SR to the form that existed before the error was introduced. The clerical error did not affect the ODCM implementing procedures or plant operation. Thus, the cumulative dose contributions from Uranium Fuel Cycle sources will continue to be maintained within the limits of 40 CFR 190 and the RETS.
Based on the above analysis, the proposed changes do not result in any hardware changes or physical alteration of the plant, and the changes will have no impact on the design or function of any structure, system, or component (SSC). As such, the SSC process 4 of 5 A . . _ . _ -- __ _ _ __ _ ~ . . _ _
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s variables, characteristics, and functional performance will be maintained consistent with j
. the event initiator and initial condition assumptions for the accident analyses. Moreover, the proposed changes will not eliminate any actions or adversely affect any SSCs required to prevent accidents or mitigate accident conditions, nor will the changes result in the degradation of any fission product barriers so as to increase the radiological consequences l of an accident. It is, therefore, concluded that operation in accordance with the proposed '
amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
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- The operation of Nine Mile Point Unit 1. in accordance with the oronosed amendment will l not create the nossibility of a new or different kind of accident from any accident l oreviousiv evaiunted.
l l The proposed changes do not result in any hardware changes or physical alteration of the plant, and the changes do not impact the design or function of any SSC. The proposed changes maintain the capability of the ECS to respond to accidents, including non-limiting small breaks, consistent with the current analyses. In addition, the proposed changes l provide. continued assurance that the radiological dose and dose rates will be maintained l- .within limits.'. The proposed changes do not alter the process variables, characteristics, or l functional performance of any SSC, do not eliminate any requirements, and do not impose any new requirements which could introduce new equipment failure modes or create new credible accidents. It is, therefore, concluded that operation in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated. I The ooeration of Nine Mile Point Unit 1. in accordance with the orocosed amendment, will not involve a sianificant reduction in a marain of safety.
l' The proposed changes do not affect the capability of the ECS to mitigate the consequences of an accident that results in a loss of feedwater or reactor isolation from the primary heat sink, or affect the capability of the ECS to aid the Core Spray System and Automatic Depressurization System in providing effective core cooling following non-limiting small breaks.- Thus, there will be no impact on the post-accident radioactive material release analyses or a reduction in margin to the associated 10 CFR 100 dose limits, in addition, the proposed changes provide continued assurance that the intent of the_ effluent monitoring requirements of 10 CFR 50 Appendix A, GDC 64,is satisfied and the dose and dose rates due to radiological effluents are maintained within the limits specified in 10 CFR 50 Appendix 1,10 CFR 20,40 CFR 190, and the RETS. Moreover, the proposed changes do not eliminate any requirements or responsibilities, nor impose any new requirements or responsibilities, or alter any physical parameters which could reduce the margin to an acceptance limit. It is, therefore, concluded that operation in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.
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ATTACHMENT C 1 NIAGARA MOHAWK POWER CORPORATION LICENSE NO. DPR 63 DOCKET NO. 50-220 1
Elialbility for Categorical Exclusion from Performina an Environmental Assessment 10 CFR 51.22 provides criteria for, and identification of, licensing and regulatory' actions eligible for exclusion from performing an environmental assessment. Niagara Mohawk Power Corporation (NMPC) has reviewed the proposed amendment and has determined that it does not involve a significant hazards consideration, and there will be no significant change in the types or a significant increase in the amounts of any effluents that may be released offsite; nor will there be any significant increase in individual ur cumulative occupational radiation exposure. Therefore, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with this license amendment application.
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' ' I l NIAGARA MOHAWK POWER CORPORATION I LICENSE NO. DPR 63 DOCKET NO. 50 220 l Marked-Un Cony of the Proposed Channes to the Current Technical Specifications (TSal l The current version of pages 290,293, and 305 has been marked-up by hand to reflect l the proposed changes.
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TABLE 3.6.14-2 (cont'd) 8tADIDACTIVE.PASEOU3 EFFLUENT MONITORING INSTRUMENTATION
- Minimum instrument Channels Operable Anellcability Action
- 3. Condenser Air Ejector Radio-activity Monitor (Recombiner discharge or mir ejector discharge)
- (g)
- a. Noble Gas Activitt 1
- b. Offgas System Flow Rate 1 (c)-
Measuring Devices c
- c. Sampler Flow Rate 1 (c)
Measuring Devices
- 4. Emergency Condenser System .j 1 per vent ****
- a. Noble Gas Activity Monitor (h)
- During o ration of the main condenser air o' ctor __ __
- During power operat whtAeve- Jempuabre /r g*h =5 my ajaega u ~s.+ c a.ca.
AMENDMENT NO.[f/ 290
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NOTES FOR TABLE 4.6.14-2
(:) At all times. .
(b) The channel calibration shall be performed using one or more of the reference standards certified by the National Bureau of Standards, t
standards that are traceable to the National Bureau of Standards or using actual samples of gaseous offiuent that have been analyzed on a system that has been calibrated with National Bureau of Standards traceable sources. These standards shall permit calibrating the system over its intended range of energy and measurement.
(c) Ths channel function test shall demonstrate that control room alarm annunciation occurs if either of the following conditions exist: ,
- 1) Instrument indicates measured levels above the Hi or Hi Hi alcrm setpoint. ,
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- 2) Instrument indicates a downscale failure.
The channel function test shall also demonstrate that automatic isolation of this pathway occurs if either of the following conditions exist:
- 1) Instruments indicate two channels above Hi Hi alarm setpoint. .
- 2) Instruments indicate one channel above Hi Hi alarm setpoint and one channel downscale.
(d) During main condenser offgas treatment system operation.
(I) The channel calibration shall include the use of standard gas samples containing a nominal:
(f) During operation of the main condenser air ejector. I i
(g) The channel test shall produce upscale and downscale annunciation.
(h) Duti cg c u e. h c o o l a n t ernbre is' yedy h WF except & h 3h4A feshn s+k & rwb nk can'cd -
AMENDMENT NO. /// 293
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t LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT
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- c. Main Condenser c. Main Condenser ,
The gross radioactivity (beta and/or gamma) rate The ra1ioactivity rate of noble gases at the of noble gases measured at the recombiner recombiner discharge shall be continuously discharge shall be limited to less than or equal to monitored in accordance with Table 3.6.14-2.
500,000 pCi/sec. This limit can be raised to 1 Ci/sec for a period not to exceed 60 days The gross radioactivity (beta and/or gamma) rate .
provided the offgas treatment system is in of noble 91ses from the recombiner discharge l operation. shall be determined to be within the limits of '
Specification 3.6.15 at the following frequencies With the gross radioactivity (beta and/or gammal by performing an isotopic analysis of a represent- !'
rate of noble gases at the recombiner discharge ative sample of gases taken at the recombiner exceeding the above limits, restere the gross discharge:
radioactivity rate to within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least Hot Shutdown within the Monthly:
next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following an increase on the
- d. Uranium Fuel Cycle recombiner discharge monitor of greater than 50%, factoring out incresises due to The annual (calendar year) dose or dose changes in thermal power level and dilution commitment to any member of the public due to flow changes.
releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less d. Uranium Fuel Cycle than or equal to 25 mrems to the total body or !
any organ, except the thyroid, which shall be . Cumulative dose contributions from liquid and limited to less than or equal to 75 mrems. gaseous effluents shall be determined in accordance with Specifications 4.6.15.a.(2),
4.6.15.b.(2) and 4.6.ht3) and in accordanc with the methodology and parameters in the Offsite Dose Calculation Manual. '
AMENDMENT NO.h 305
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