ML20237G470

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Safety Evaluation Supporting Amend 7 to License NPF-36
ML20237G470
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/14/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20237G440 List:
References
NUDOCS 8708240097
Download: ML20237G470 (5)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.

7 TO FACILITY OPERATING LICENSE NO. NPF-36 LONG ISLAND LIGHTING COMPANY l

SHOREHAM NUCLEAR POWER STATION DOCKET NO. 50-322 1,0 INTRODUCTION By letter dated November 16, 1985, Long Island Lighting Company (the licensee) requested an amendment to Facility Operating License No. NPF-36 for the Shoreham Nuclear Power Station. The proposed amendment would:

(1) change the Technical Specifications (TS) Surveillance Requirement (SR) 4.4.3.1.c by changing the footnote from "*not required if containment is closed and inerted." to "*not required if containment is closed.", (2) Revise TS 3/4.3.7.9 to reflect changes in the number and type of plant fire detectors. The licensee's letter was supplemented by letter dated December 9, 1985, in which revisions to the locations of fire detectors were made to reflect as-installed locations.

2.0 EVALUATION l

(1) Technical Specification SR 4.4.3.1.c, Reactor Coolant System Leakaoe Detection Systems s

Surveillance Requirement (SR) 4.4.3.1.c. deals with the surveillance tests for the primary containment (drywell) air coolers Condensate Flow Indication System (CFIS). The CFIS is one of the leak detection systems for the Reactor Coolant System (RCS) available at SNPS. The existing TS requires the performance of a channel functional test for the CFIS at least once per 31 days during Plant Operational Condicions 1, 2 and 3 to demonstrate the system operability during the above plant conditions.

However, it exempts the need for the test provided the primary containment is both closed and inerted. The proposed SR exempts.the test performance provided the primary containment is closed but not also inerted. On request from staff for information relating to the requested relief, by letters dated March 18 and October 8 of 1986, the licensee stated the following:

1.

The channel to be functionally tested for the CFIS is a bistable channel which requires (per definition contained in Section 1.6 of TS) injection of a signal into the sensor for performance of the channel functional test.

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2.

The sensors cre two flow switches, one for each of the two primary containment (or drywell) air coolers condensate flow. These are located in the fan cooler condensate drain lines at Elevation 63 feet in the drywell.

Flow rates equal to or greater than 1.3 gpm will cause the switch to complete a circuit that causes an alarm to annunciate in the control room.

3.

During the period January 31, 1984 - August 14, 1986, 19 channel functional tests were performed for the CFIS and 18 of these gave acceptable results.. For the remaining one, the high flow alarms were properly triggered during the channel function test, but one of the flow switches failed to reset (July 7,1986). Three tests performed subsequently after correcting the problem (i.e., removal of' a foreign material that was blocking the flow discs) gave acceptable results.

The licensee further stated that the performance of the channel functional tests for the CFIS will require prinary containment entry. This will require deinerting the primary containment and reducing the reactor power level to less than ? percent thermal power to reduce operator exposure to radiation to acceptable levels.

The licensee stated that requiring the performance of channel functional tests at least once every 31 days during

,i plant Operational Conditions 1, 2 and 3 will therefore result in frequent interruptions of plant operation, particularly, during the Power Ascension 1

Test Program (PATP) for SNPS.

In this context, the licensee noted that Supplement 9 to Shoreham Nuclear Power Station (SNPS) SER (Section 6.2.4) had stated that it would be better to operate the reactor without inerting the primary containment during the performance of the PATP for SNPS.

The licensee further concluded that past performance (see Item 3 given above) has demonstrated the CFIS to be a reliable and dependable leak detection system for the RCS which supports a longer time interval for surveillance test than the 31 days interval normally required for the system.

Based on review of the above submittals, the staff requested information on any backup system that could be used to determine the operability of the CFIS during Plant Operational Conditions 1, 2 and 3, in the event, demonstration of the operability of the system by cha'nnel functional tests on the system is not feasible for the reasons stated above.

By letter dated March 30, 1987, the licensee provided the requested information.

Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary leakage Detection Systems" requires that at least three separate leak detection systems be provided to detect the RCS pressure boundary leakage so that corrective action can be taken in a timely manner to reduce the leakage to within acceptable limits specified in the plant TS.

SNPS TS lists the following four systems out of which three systems are required to be operable during plant operational conditions 1, 2 and 3:

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The primary containment atmosphere particulate radioactivity monitoring systems, 2.

The primary containment sump flow monitoring system, and 5

3.

Either the primary containment air coolers condensate flow indication system or the primary containment atmosphere gaseous radioactivity monitoring system.

7 The plant TS also specifies the SR for each of these systems to demonstrate their operabilities.

In the March 30, 1987 submittal, the licensee stated that, in the event, no channel functional test or channel calibration test has been performed within the preceding 31 days on the CFIS, they will utilize the existing two drywell moisture indicators as a backup system to determine the CFIS operability by monitoring the drywell moisture content once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These moisture indicators are located inside the primary containment air coolers influent ducts. The licensee has determined that the drywell air coolers influent duct humidity ratio of 0.0381 (MASS water / MASS dry air) would correspond to the primary containment air coolers condensate flow of 1.3 gpm, the alarm set point for the CFIS.

The licensee stated that, in the event, the drywell air coolers influent duct humidity ratio equals or exceeds the above correlation value and additionally the expected annunciation of the alarms for the CFIS do not occur in the control room, the operations personnel will conclude the CFIS to be inoperable. The licensee committed to upgrade the drywell moisture indicators to utilize them as described above. The upgrade will enable 1

the operators to read off the indicating instruments i.e., the chart S

recorders, the influent duct humidity ratio for the two air coolers. The i

chart recorders will be on the front of the Reactor Building Ventilation W

panel in the control room.

The licensee further committed to modify the plant procedures to implement the above approach for determining the operability of the CFIS.

Specifically, the revised procedures will spell 3

out how and when the drywell moisture indicators are to be used to determine the operability of the CFIS.

y The staff notes that the CFIS does not send any automatic signal to any safety-related system such as the Reactor Protection System or the Emergency Core Cooling System for initiating any action.

Further, as mentioned above, performance of channel functional tests on the system at an interval of 31 days during plant operational conditions I, 2 and 3 would involve frequent interruptions of normal plant operation.

Therefore, the staff agrees with the licensee that if other means for determining the operability of the CFIS during the above plant conditions are available, they can be used in lieu of the 32-day surveillance tests.

Based on the licensee's March 30, 1987 submittal discussed above, the staff finds that

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the drywell moisture indicators can serve as an effective backup system for determining the operability of the CFIS when such determination by

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performance of channel functional tests on the system is not feasible.

The staff further finds that the licensee's commitment to revise the existing plant procedures will provide the needed operator guidance for s

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-E determining the CFIS operability. Based on the above, the staff has determined that the proposed use of two drywell moisture indicators under certain circumstances (see above for the circumstances) to determine the operability of the CFIS along with the performance of other surveillance tests specified in the plant TS is a reasonable approach to demonstrate the operability of at least three leak detection systems for the RCS. The staff, therefore, finds that the proposed TS change complies with the intent and purpose of Regulatory Guide 1.45 and is, therefore, acceptable.

(2) Technical Specification 3/4.3.7.9 Fire Detection' instrumentation The modification in the member and type of plant fire detectors is in response to the findir;gs of NRC Inspection 84-86.

NRC Inspection Report-84-46-05 required the re-working of the fire detectors in all safety related areas to comply with the requirements of National Fire Protection Association (NFPA) Standards 72D and 72E regarding density and location of detectors. By letter dated January 29, 1985, the licensee committed to make modifications to the fire detection systems to be in conformance with the above-referenced standards. Upon evaluation of the committed l

change, the staff closed Inspection Item 84-47-05 in Supplement No. 9 to the Safety Evaluation Report related to the operation of Shoreham Nuclear Power Station (NUREG-0420, SSER-9, Section 9.5.2.4 Fire Protection System).

Since these medications were made to comply with an NRC Inspection item and since the staff has found the committed changes to be acceptable following an evaluation as documented in SSER-9, we find this proposed change to the TS to be acceptable.

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3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance require-(

ments. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment' meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of this amendment.

4.0 CONCLUSION

The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Reaister (50 FR 51625) on December 18, 1985, and consulted with the State of New York.

No public comments were received, and the State of New Yor'. did not have any comments.

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The staff has concluded, based on the considerations discussed above, that:

(1)' there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's

- regulations and the issuance of this amendment will not be inimical to the t'*

common ' defense and the security nor to the health and safety of the public.

Prinicipal Contributor:

T. Chandrasekaran R. Lo Dated: August 14, 1987 4

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