ML20214U774

Proposed Tech Specs,Incorporating Changes to Ph Requirements & Correcting Error on Notes for Table 3.2.A Re Adminstrative Controls

ML20214U774
Person / Time
Site:	Cooper
Issue date:	11/24/1986
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
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ML20214U755	List: ML20214U751 ML20214U774
References
NUDOCS 8612090392
Download: ML20214U774 (8)

Text

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- Attrchment I l

Revised Technical Specifications for pH Revised Pages: 134 New Page: 134a During an inspection (IER 50-298/85-24), it was noted that the Technical Specifications for chemistry requirements are not clear.concerning pH. This change clarifies this section to make it clear what pH requirements are in '

effect for what condition. Also, this change takes credit for a 5.3-8.6 pH range in the depressurized condition as approved in the Standard Technical Specifications, and noted to the District (see letter J. E. Gagliardo (NRC-RIV) to J. M. Pilant (NPPD) dated January 27, 1986).

Evaluation of this' Revision with Respect to 10CFR50.92 A. The enclosed Technical Specification change is judged to involve no significant hazards based on the following:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation:

This proposed change does not change existing equipment, surveillances, or procedures. This change adds clarity to present Technical Specifications by rewording existing sections. The pH requirements being clarified by this proposed change were originally added by Amendment 27 to the Technical Specifications (SER dated May 24, 1976). The conclusions made in that SER will not be altered but simply clarified. Utilizing the 5.3-8.6 pH range in the depressurized condition is allowed by Standard Technical Specificationc. As a result, it is the District'c assessment that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?

Evaluation:

This proposed change does not make any changes to the present mode i of operation, but adds clarity to ambiguous wording, and takes <

credit for a pH range (depressurized condition) allowed by Standard Technical Specifications. Because the proposed change does not

! create a new mode of operation, it does not create the possibility

of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a j margin of safety?

l F612090392 86112 i PDR ADOCK 05000

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W-Evaluation:

One portion lof this change provides clarification while the other one takes credit for a lower limit ' allowed by Standard Technical Specifications. The clarification of the Technical Specifications does not result in a significant reduction in a margin of safety.-

Within the co.tfines of the Standard Technical Specifications and as allowed under'.-'the District's fuel warranty, the addition of an expanded pH limit while depressurized, will not result in a significant. reduction in a margin of safety.

B. Additional basis . for proposed no significant hazards consideration determination:

The commission has provided guidance :oncerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870). In reviewing those examples for this request, it was found that this request does not clearly fall into the scope of any of the examples provided.

P LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.6.B. (cont'd)

• ** (" ""

When the reactor is pressurized (i.e. b. If the gross activity counts of a'

2. sample indicate an activity

>212*F) and during operation up to 10% c neentration above 3.1 pCi/gm of of rated power, the following reactor d - equivalent I-131, an isotopic coolant system chemistry limits shall at / sis shall be performed and apply:

quantitative measurements made to Normal limits, determine the dose equivalent a.

I-131 concentration.

Conductivity (umho/cm at 25'C) 12.0 c. An isotopic analysis of a reactor coolant sample shall be made at Chloride (ppm) 10.1 least once per month, pH 5.61pH18.6 2. Reactor coolant shall be continuously, monitored for conductivity, or, when Should these limits be exceeded the continuous conductivity monitor is for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one inoperable, the reactor coolant shall continuous time interval, be in at be analyzed, least the HOT SHUTDOWN condition within the next I? hours and (or a. At least once every 4 Scurs for if already in the HOT SHUTDOWN conductivity, chloride ion content, condition) be in the COLD SHUTDOWN and pH prior to startup, during the condition within the following 24 operation of the reactor and during hours. hot standby.

3. During operation in excess of 10% of b. At least every 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for rated power, the following reactor conductivity, chloride ion content, coolant system chemistry limits shall and pH when the reactor is not apply: pressurized.

a. Normal limits. 3. Prior to startup, during the operation of the reactor and during hot standby, Conductivity a sample of the reactor coolant shall (umho/cm at 25'C) 11.0 be analyzed:

Chloride (ppm) 10.2 a. At least every 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for conductivity and chloride ion pH 5.61pH18.6 content when the continuous conductivity monitor reading is

b. Time limit. Should the ~

<0.7 umho/cm at 25'C.

conductivity or chloride limits in 3.6.B.3.a. be exceeded for more b. At least every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for than 336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> per year or the conductivity and chloride ion conductivity, chloride or pH limits content when the continuous for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during one conductivity monitor reading is continuous time interval, be in at >0.7 but <2.0 umho/cm at 25'C.

least the STARTUP/ HOT STANDBY mode within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. c. At least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for conductivity and chloride ion

c. Maximum limits. content when the continuous conductivity monitor reading is Conductivity >2 but 13.5 umho/cm at 25'C.

(umho/cm at 25'C) 110 Chloride (ppm) 10.5

-134-

l LIMITING CONDITIONS FOR OPERATION SURVEILLA!!CE REQUIREMENTS Should these maximum limits be d. At least every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for exceeded, be in the COLD SHUTDOWN conductivity, chloride ion content, condition within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and pH, when the continuous conductivity monitor reading is

4. At all other times, the following >3.5 umho/cm at 25'C. l reactor coolant system chemistry limits shall apply: 4 When the reactor is not pressurized, a sample of the reactor coolant shall be

a. Normal limits, analy=ed at least every 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for conductivity and chloride ion content Conductivity and pH. l (umho/cm at 25'C) 110.0 Chlorides (ppm) <0.5 pH 5.3fpH<8.6 ,

Should the conductivity or pH limits be exceeded for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during one continuous time ,

interval, or should the chloride l limit be exceeded for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during one continuous time interval, perform an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the reactor coolant system. The structural integrity of the reactor coolant system shall be determined to remain acceptable for continued operation (prior to operation in other than the COLD SHUTDOWN conditions).

5. The provisions of Specification 1.0.J, are not applicable.

-134a-i

Attachment 2 Revised Technical Specifications for Protective Instrumentation. Administrative Controls Revised Pages: 52a, 229 Amendment 62 (dated 05/20/80) was responsible for removing certain Technical Specification requirements related to Reactor Water Cleanup System High Temperature. This amendment deleted the stated requirement, but in error Item 4 under Group 3 for Table 3.2. A (page 52a) was not deleted. (The item which should have been deleted was only associated with the instrument that was deleted). As a result, this change will remove the referenced item to bring page 52a into line with Amendment 62. Additionally, this proposed change requests a revision to page 229 (Administrative Controls) to provide clarification of Section 6.4.2.H. It ois felt that this item is somewhat ambiguous and that clarifying this section now to be more in-line with Standard Technical Specifications will prevent future misinterpretations.

Evaluation of this Revision with Respect to 10CFR50.92 A. The enclosed Technical Specific'ation change is judged to involve no significant hazards based on the following:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation:

Neither the deletion of a requirement previously removed by another amendment, or clarification of another section will change existing equipment, surveillances, or procedures. This change adds clarity to one section and corrects an error in another section. As a result, it is the District's assessment that the intent and purpose of these sections do not change and the change does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?

Evaluation:

This proposed change does not make any changes to present modes of operation. Therefore, the proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Evaluation:

The proposed change does not make any changes to the present mode of operation, but adds clarity to ambiguous Technical Specifications.

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Therefore, the proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

B. Additional basis for proposed no significant hazards consideration determination:

The commission has proviiled guidance concerning the application of the standards for determininf; whether a significant hasards consideration exists by providing certain examples (48CFR14870). The examples includet

"(i) A purely administrative change to Technical Specifications. For example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature." It is the District's belief that the proposed change is encompassed by the above example.

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t NOTES FOR TABLE 3.2.A (cont'd.)

Group 2 i Isolation Signals l

1. Reactor Low Water Level (+12.5 in.)

2. High Dry Well Pressure (1'2 psig)

Isolations:

1. RHR Shutdown Cooling System

, 2. Vessel head spray Dryvell floor and equipment drain sump discharge lines.

3.

4 TIP ball valves

5. Group 6 isolation relays

! Group 3 '

i Isolation Signals:

1. Reactor Low Water Level (+12.5 in.)

2. Reactor Water Cleanup System Hi,n Flow (200% of system flow)

! 3. Reactor Water Cleanup System High Area Temperature (1 200*F)

! I Isolations:

1. Reactor Water Cleanup System Group 4 Isolation Signals:

Provided by instruments on Table 3.2.B (HPCI)

Isolationst Isolates the HPCI steam line .

Group 5 Isolation Signals:

Provided by instruments on Table 3.2.B (RCIC)

Isointions:

Isolates the RCIC steam line.

Group 6 t

Isolation Signalst

1. Group 2 Isolation Sianal

2. Reactor Building H&V Exhaust Plenum High Radiation (<100 mr/hr)

-52a-

. . ~ r *^

• 6.4.2.G (cont'd) -

f- . .

usageevaluationperthe{SMEBoilerandPressureVesselCode Section III was performed for the conditions defined in the design specification. The locations to be monitored shall be:

a. The feedwater nozzles

b. The shall at or near the waterline

c. The flange studs

2. Monitoring, Recording, Evaluating, and Reporting

a. Operational transients that occur during plant operations will, at least annually, be reviewed and compared to the transient conditions defined in the component stress report for the locations listed in 1 above, and used as a basis for the existing fatigue analysis.

b. The number of transients which are comparable to or more severe ,

than the transients evaluated in the stress report Code fatigue usage calculations will be recorded in an operating log book.

For those transients which are more severe, available data, such as the metal and fluid temperatures, pressures, flow rates, and, other conditions will be recorded in the log book.

c. The number of transient events that exceed the design specification quantity and the number of transient events with a severity greater than that included in the existing Code fatigue usage calculations shall be added. When this sum exceeds the predicated number of design condition events by twenty-five ,2a fatigue usage evaluation of such events will be performed for the affected portion of the RCPB.

H. Records of current individual plant staff members showing qualifications and the completion of training.

I. Records for Environmental Qualification which are covered under the pro-visions of Specification 6.3.

J. Records of the service lives of all hydraulic and mechanical snubbers noted in 3.6.H.1, including the date at which the service life commences and associated installation and maintenance records.

6.4.3 2 Year Retention Records and logs relating to the following items shall be kept for two years.

A. The test results, in units of microcuries, for leak tests of sources performed pursuant to Specification 3.8. A.

B. Records of annual physical inventories verifying accountability of the sources on record.

1. See paragraph N-415.2 ASME Section III, 1965 Edition.

2. The Code rules permit exclusion of twenty-five (25) stress cycles from secondary stress and fatigue usage evaluation. (See paragraphs N-412(t)(3) and N-417.10(f) of the Summer 1968 Addenda to ASME Section III, 1968 Edition.)

-229- 5/20/85