ML20215E609
| ML20215E609 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/09/1987 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20215E597 | List: |
| References | |
| NUDOCS 8706220043 | |
| Download: ML20215E609 (10) | |
Text
4 ATTACHMEMT_
A Revise the Technical Specifications as follows:
Remove Page Insert Page 6
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TABLE 3.3-6 (Continued)
ACTION STATEMENTS 1
' ACTION 19 -
With the number of channels OPERABLE less than required by the-Minimum Channels OPERABLE requirement, perform area surveys of_ the monitored area with portable monitoring instrumentation at lease once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
ACTION 20 - -With the number of channelr OPERABLE less'than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.6.1.
ACTION 21 -
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the
. applicable ACTION requirements of i
specifications 3.9.12 and 3.9.13.
l ACTION 22 -
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9.
ACTION 36 -
With the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, either l
restore the inoperable Channel (s) to OPERABLE status I
within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:
I a)
Initiate the preplanned alternate method of monitoring the appropriate parameter (s), and l
b)
Return the channel to OPERABLE status within 30
- days, or, explain in the next Semi-Annual Effluent Release Report why the inoperability _was not corrected in a timely manner.
ACTION 41 -
a)- With the number of Unit 1 OPERABLE channels one less than the Minimum Channels OPERABLE requirement:
- 1. Verify the respective Unit 2
control room i
radiation monitor train is OPERABLE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> j
and at least once per 31 days.
I
- 2. With the respective Unit 2 control room radiation monitor train inoperable, suspend all operations involving movement of irradiated fuel within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and restore the Unit 1
control room radiation monitor to OPERABLE status within 7 days or isolate the control room from the outside atmosphere by closing all series air intake and exhaust isolation dampers, unless the respective Unit 2
control room radiation monitor train is a
restored to OPERABLE status within 7 days.
BEAVER VALLEY - UNIT 1 3/4 3-35 1
PROPOSED WORDING 1
l
TABLE 3.3-6 (Continued) 1 ACTION STATEMENTS l
l ACTION 41-(Continued) b)
With no Unit 1
control room radiation monitors j
OPERABLE:
1.
Verify both Unit 2
control room radiation monitors are OPERABLE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 31 days.
2.
With either Unit 2 control room radiation monitor inoperable, suspend all operations involving movement of irradiated fuel within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and restore the respective Unit 1
control room radiation monitor train to OPERABLE status within 7
days or isolate the control room from the outside atmosphere by closing all series air intake and exhaust isolation dampers, unless the respective Unit 2 control room radiation monitor train is restored to OPERABLE status within 7 days.
3.
With no Unit 2
control room radiation monitors
- OPERABLE, immediately isolate the combined control room by closing all series air intake and exhaust isolation dampers and be in at least HOT STANDBY within the next. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
I l
I i
1 BEAVER VALLEY - UNIT 1 3/4 3-35a PROPOSED WORDING
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ATTACHMENT B
Proposed Technical Specification Change No. 135 No Significant Hazard Consideration Description of amendment request:
The wall separating the Unit 1 and Unit 2 control rooms was removed to provide a common control room area for the two units.
The Beaver Valley Unit 2 accident analyses indicate that the control room must be isolated on a control room high radiation signal in order to meet 10CFR 50, Appendix A, General Design Criteria 19.
This is described in Sections 6 and 15 of the Unit 2
FSAR.
As a result, two area radiation monitors were added to the Unit 2
side of the control room and two area radiation monitors (RM-RM-218A and B) are installed in the Unit 1 side of the control room in accordance with DCP-711.
These monitors initiate control room ventilation system isolation and the Control Room Emergency Bottled Air Pressurization System (CREBAPS) on a
high radiation signal.
Since each control room area of the combined two unit control room is monitored by two monitors, a degree of additional redundancy exists.
A total of four monitors are provided and are powered from their respective units emergency power source.
There I
are two A train monitors, one on the Unit 1 side and one on the Unit 2
- side, and two B train monitors.
Each train is capable of closing its respective, train related (not unit related),
control room isolation damper, therefore, all series normal air intake and exhaust isolation dampers receive two separate and independent radiation monitor signals.
While this Technical Specification change request l
addresses the Unit 1
radiation
- monitors, the Unit 2
radiation monitors are similarly maintained operable via the Unit 2 Technical Specifications.
The following changes have been incorporated:
l l
1.
Page 3/4 3-34, Table 3.3-6 add item 1.c. Control Room Isolation l
(RM-RM-218A and B).
j i
Minimum Channels Operable - 2 control room radiation monitors are provided.
i Applicable Modes -
1, 2, 3, 4, 5## and 6## to reflect the l
accident analysis results.
The note (in I
either unit) requires operability of l
these monitors if either Unit 1 or Unit 2 is in one of these applicable modes.
This will ensure the control room per-sonnel are protected when conditions exist for the potential release of radia-tion due to a postulated accident.
The l
- note specifies applicability during movement of irradiated fuel.
Setpoint -.47 mR/hr.
Measurement Range 2 - 10s mR/hr.
2.
Page 3/4 3-35, Action 41 Action 41 This action statement was written so that control room isolation is not immediately required in the event the control room radiation monitors are inoperable.
If the control room ventilation system
~Attcchmsnt.B (Continurd)
TSCR'lA-135 Page 2 were isolated from the outside atmosphere, to reflect inoperable _ control room radiation monitors, and a high l
radiation condition existed outside the control room, CREBAPS would not be automatically initiated on a high radiation signal since the control room radiation monitors would not be monitoring the control room air.
Therefore, to ensure the control room air is continuously monitored and to provide for the automatic initiation of CREBAPS,'
the control room ventilation system will not be immediately isolated because of inoperable radiation monitors.
The following provides a description of each j
individual action requirement:
I a)1.
Provides the course of action to be performed when j
one Unit 1
control room radiation monitor is j
?
This action statement requires verification that the respective Unit 2 monitor in the same train is operable.
Therefore, control room isolation and CREBAPS initiation are available for that train by the other radiation monitor in addition to the radiation monitors in the other train.
i a)2.-
Provides the course of action to be performed.when two control room radiation monitors in'the same train are inoperable.
The Train A
radiation
- monitors, one monitor at Unit 1 and one monitor at Unit 2:,
provide isolation ~ signals to the Train A control room ventilation system dampers.
The train j
A ' dampers are in series with the Train B dampers in the respective units ventilation system.
The Train B
radiation monitors and control room ventilation system dampers are also designed this way.- If both monitors in one train are inoperable that train is then inoperable, therefore, the action requires suspending the movement of irradiated fuel (allows for movement to a safe configuration) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />
)
and restoring at least one of the monitors in that j
train to operability within 7 days or isolate the i
control room.
Control room isolation and CREBAPS initiation is available by the radiation monitors in the other train.
Therefore, this requirement is provided to ensure an inoperable radiation monitor is repaired within a reasonable time period so that the capability is available to isolate the control room and initiate CREBAPS when required.
1 b)l.
Provides the course of action to be performed when both Unit 1
radiation monitors are inoperable and both Unit 2 radiation monitors are operable.
This
1 Attachment B (Continued)
TSCR 1A-135 Page 3 action statement requires verification within 1
)
hour and once per 31 days that both Unit 2
radiation monitors are operable.
This ensures at least one monitor in each train is available to perform control room isolation and CREBAPS initiation.
b)2.
Provides the course of action to be performed when both Unit 1
control room radiation monitors are inoperable and one Unit 2
radiation monitor is inoperable.
This action statement requires suspending movement of irradiated fuel within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (allows for movement to a safe configuration)
J and restoring one Unit 1
radiation monitor to l
operability within 7
days or isolate the control
- room, unless one Unit 2 radiation monitor has been restored to operability.
Therefore, this f
requirement provides for limited movement of irradiated fuel and ensures an inoperable monitor j
is repaired within a
reasonable time period to ensure the capability is available to isolate the control room and initiate CREBAPS when required.
b)3.
Provides the course of action to be performed when both Unit 1 and both Unit 2 control room radiation monitors are inoperable.
This action statement requires isolating the combined control room from the outside atmosphere immediately and shutdown the plant.
3.
Page 3/4 3-36, Table 4.3-3 add item 1.c to reflect the change to Table 3.3-6.
The note applicable to the monthly Channel Functional Test for the Control Room Isolation radiation monitors specified on Table 4.3-3 provides clarification of the required testing.
In accordance with the definition of a
Channel Functional Test a simulated signal shall be injected into a
channel as close to the primary sensor as practicable to verify operability including alarm and/or trip functions.
The trip functions involve isolating the control room by closing the control room intake and exhaust dampers and actuating the CREBAPS solenoid valves.
Since these isolation dampers and solenoid valves would be actuated by both the Unit 1 and Unit 2 radiation monitors this would lead to accelerated degradation of the components and potentially increase the likelihood of leakage or failure.
In addition, the control room isolation dampers and solenoid valves are exercised in accordance with the surveillance requirements applicable to Specification 3.7.7.1.
Therefore, to reduce the potential for excessive equipment actuation which leads to increased component leakage or failure the control room isolation dampers and CREBAPS solenoid valves will not be actuated during these Channel Functional Tests.
j i
Attachment B (Continued)
TSCR 1A-135 Page 4 Basis for no significant hazard determination:
Based on the criteria for determining whether a significant hazards consideration 4
exists as setforth in 10 CFR 50.92(c), plant operation in accordance with the proposed amendment would not:
1.
Involve a
significant increase in the probability of occurrence or the consequences of an accident previously evaluated because:
The control room radiation monitors were installed to provide automatic isolation of the control room from the outside atmosphere and automatically initiate CREBAPS on a high radiation signal.
This will preclude the addition of unmonitored makeup air to the control rocm and ensure control room personnel will not be subjected to a
radiation exposure in excess of GDC-19 limits following a
postulated accident.
The addition of these monitors provide an improved monitoring capability from what previously existed.
Their purpose is to isolate the control room and initiate CREBAPS and therefore they do not interface with other components in such a
manner which would increase the probability of occurrence of any accident previously evaluated.
These monitors have been designed and installed in accordance with safety related procedures to assure adequate separation and isolation.
The accidents these monitors are designed to protect against have been defined in the Unit 2 FSAR and are a result of different licensing criteria applying to unit 2 compared to Unit 1.
Therefore, the equivalent accident analysis for Unit 1 does not exist as part of its licensing basis and as such there is no significant increase in the consequences of an accident previously evaluated.
The applicability statement requires operability of the monitors when either Unit 1 or Unit 2 is in modes 1,
2, 3,
4 or mode 5 or 6 during movement of irradiated fuel.
These are the plant ope. rating conditions at which the postulated accidents could occur and at which radiation releases may have the potential to exceed the limits of GDC 19.
The action statements provide an acceptable alternative when conditions arise that may affect the radiation monitor operability status and provide for the timely repair of inoperable monitors.
This will ensure the monitors will not be out of service for an extended period of time and that monitored makeup air can be added to the control room to assure an adequate number of air changes occur in maintaining the control room environment.
The action statements were developed to assure that if one complete train of input signals to the respective dampers are inoperable, then action is to be taken in accordance with other action statements for ESF equipment.
(i.e., when one train of ESF equipment is inoperable, restore it to operable status within a finite period of time, otherwise take actions to protect the plant from the hazard).
These actions require returning the ESF equipment to an operable status in an expedited manner to assure single failure criteria remains satisfied.
Therefore, the addition of these monitors will not affect the probability of an accident and the setpoint was chosen to provide a low probability of spurious actuation to limit interference with normal plant operation and will also maintain control room personnel exposure within GDC 19 limits following postulated accident conditions.
Attachment B (Continued)
TSCR 1A-135 Page 5 2.
Create the possibility of a
new or different kind of accident i
from any previously analyzed because:
The addition of these monitors adds the capability to monitor the control room ventilation system makeup air for high radiation levels.
In the event the radiation monitor setpoint is exceeded the control room will be automatically isolated from the outside atmosphere and the CREBAPS will be initiated.
This protective action is i
consistent with actions taken for control room operator
{
protection for the Unit 1 DBA.
These monitors provide increased i
protective actions beyond those which previously existed.
A new or different kind of accident is not created since the monitors themselves actuate ESF systems for events not previously evaluated.
This ensures that control room personnel will be protected in accordance with GDC-19 and will not create the possibility of a new or different kind of radiation release.
3.
Involve a
significant reduction in a margin of safety because:
These monitors will ensure that the control room will be automatically isolated from the outside atmosphere and CREBAPS will be initiated on a
high radiation signal.
The margin of safety defined in Bases sections 3/4.3.3.1 Radiation Monitoring i
Instrumentation and 3/4.7.7.1 Control Room Emergency Habitability
{
System will be enhanced by the addition of these monitors to the j
technical specifications.
Therefore, these monitors will not i
reduce the margin of safety for any technical specification.
Conclusion j
control room radiation monitors were installed to monitor the j
control room atmosphere and provide automatic isolation of outside
]
makeup air and CREBAPS initiation on a high radiation signal.
The addition of these monitors and the proposed technical specification changes will ensure that radiation exposure to control room personnel will not exceed the limits of GDC 19.
These changes will not increase the likelihood of a malfunction of safety related equipment, increase the consequences of an accident previously analyzed, nor create the possibility of a
malfunction different than previously evaluated.
Therefore, based on the
- above, it is proposed to characterize the changes as involving no significant hazard.