ML20236N221

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Discusses Interpretation of Plant TS Re Acceptability of Grab Sampling on Leakage Detection Sys within Meaning of TS 3.14A
ML20236N221
Person / Time
Site: Maine Yankee
Issue date: 05/05/1997
From: Charemagne Grimes
NRC (Affiliation Not Assigned)
To: Milano P
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 NUDOCS 9807150053
Download: ML20236N221 (4)
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. ,,, May S. 1997 MEMORA80UM FOR: Patrick D. Milano, Acting Director Project Directorate, PDI-3 Division of Projects, NRR I

FROM: Christopher I. Grimes, Chief, Technical Specification Branch s M Associate Director for Projects, NRR

$UBJECT: INTERPRETATION Of MAINE TANKEE TS REGARDING THE ACCEPTABILITY Of GRAB SAMPLING AS A LLtyAGE DETECTION SYSTEM WilHIN THE MEANING OF 15 3.14 A in a work request dated March 25, 1997, Dan Dorman, the Maine Yankeee project manager asked the Technical Specification Branch (158) to provide a view on the acceptability of the Itcensee's interpretation that conducting daily containment air grab samples meets the requirement af TS 3.14 A for having an operating leakage detection systes sensitive to radioactivity in the containment. After reviewing the documentation supplied with the request, the Maine Yankee technical specifications (TS) and associated bases, and the plant final Safety Analysis Report, it is TSB's position that the Itcensee's practice is hot in compliance with the 15. A discussion of that review is provided below.

Maine Yankee IS 3.14 A states:

  • When the reactor is above 21 power, two reactor Coolant leak detection systees of different operating principles shall be operating, with one of the two systems sensitive to radioactivity in the containment.

Remedial Action: If two reactor coolant leakage detection systems are operable but netther is sensittve to radioactivity, a system sensitive to radioactivity must be made operable within 48 hrs."

The 15 Basis associated with 15 3.14 A states:

" Reactor coolant system brakage may be indicated by one or more of the following methods:

1. Primary system water balance inventory.
2. Containment sump level.
3. Containment air particulate monitor and/or radio gas monitor. - , _

CONTACT: Jim Luehman, 158/NRR 415-3150 NRC HLE CENTER COPY n

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P. Milano Ma, 8 1997 l

4. Containment atmospherte humidity and/or air ejector effluent monitor.
5. Steam generator blowdown monitor anti /or air ejector effluent monitor.

Leakage may be indicated and/or identified by the following routine and special plant surveillance operations: l l

1. Primary system hot leak test. (Involves monitoring steady-state drop in l Volume Control Tank Level).
2. Direct observation from accessible locations within the containment.
3. Samp1tng and analysts of containment atmosphere, steam generator blowdown and air ejector effluent for radioactive and non-radioactive tracers.
4. Sampling and analysts of steam generator steam samples.*

The 15 requires an " operating" system and the periodic samp1tng does not meet that requirement. Further, sampling once every day does not provide equivalent monitoring to that of a continuous monitoring system (such as the Containment gas RMS or the Containment APD RMS) which, typically has a response ttee on the order of one hour. Despite the Itcensee claim that its position is consistent with the T5 Basts, the discussion in the Basis provides no clear support to the licensees interpretation.

NRC's generic position (Regulatory Guide 1.45, May 1973), on what constitute adequate leakage monitoring systems, discusses only continuous monitoring systeus or systems that would *be operating." While Maine Yankee apparently was'and is not required to comply with the positions stated in Reg. Guide 1.45, those positions would have been instructive to the Itcensee when it made the interpretation in 1985. Sampling on a daily basis, while recognized in the standard 15. spectitcally as an acceptable remedial action for certain out-of-service leakage monitoring systems, is not itself considered a leakage monitoring system within the meaning of the standard 15. Therefore, based on the above discussion, it is TSB's conclusion that sa'mpling and analysis does not itself, generically or within the meaning of the Maine Yankee 15, constitute a leakage detection system.

In response to the inspection finding that raised this issue, the licensee maintained that its interpretation is "even more conservative with respect to l standardized Tech. Specs." Whether or not the Maine Yankee TS is more or less restrictive than the standard 15 is not rea.11y relevant. The issue under

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I P. Milano wa, 5. 1997 consideration is whether the licensee's interpretation is permissible under the wording of the plant TS. As a separate matter, if the Itcensee concludes that the standard TS of fer more flexiblitty than its present TS then, conversion to thee should be made a priority.

The staff's position on TS 3.14 differs from that of the Itcensee. However, given the less than clear intent of the TS Basis discussion, the licensee's interpretation of the 15, while incorrect, is not unreasonable. Therefore, rather than focusing on the Itcensee's past incorrect appitcation of the TS, staff efforts should be directed toward ensuring that for the future, the Itcensee understands the staff's position and either complies with it or l proposes to amend the TS, as necessary. Enforcement action for this violation should be coordinated with the Office of Enforcement.

cc: C. Hehl, Region 1 J. Zwolinskt m.

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consideration is whether the licensee's interpretation is permissible under the wording of the plant TS. As a separate matter, if the Itcensee concludes l that the standard TS offer more flexibility than its present TS then, conversion to them should be made a priority.

The staf f's position cri TS 3.14 dif fers from that of the licensee. However, given the less than clear intent of the 15 Basts discussion, the licensee's i

interpretation of the TS, while incorrect, is not unreasonable. Therefore, l rather than focusing on the licensee's past incorrect application of the TS, staff efforts should be directed toward ensuring that for the future, the licenste understands the staff's position and either complies with it or proposes to amend the TS, as necessary. Enforcement action for this violation should be coordinated with the Office of Enforcement.

1 cc: C. Hehl, Region !

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\ DISTRIBUTION:

FILE CENTER TSB R/F CIGrimes M o9bqt(,C6C JGluehman O D0orman bbMrmcn ,OIE.

DOCUMENT NAME: G:\JGL\ LEAK.MY *See previous concurrences 0FFICE TS8:ADPR C:EMCB:DE:NRR OGC 0:0E C:TSB:ADPR:NRR NAME JGluehman JStrosnider RWeisman JLieberman CIGrimes bl. 9 DATE 04/4/97* 04/9/97* 05/1/97* 05/3/97* 05/6/97 0:FICIAL RECORD COPY l

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