ML20248L329

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Proposed Tech Specs Incorporating Proposed Changes Re Seismic Monitoring Into HNP TS
ML20248L329
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 06/02/1998
From:
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20248L325 List:
References
GL-95-10, NUDOCS 9806110091
Download: ML20248L329 (20)
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.t' Docket No. 50 213 CY-98-084 i

Attachment 1 i Haddam Neck Plant Proposed Revision To The Technical Specifications Marked-Up Pages i

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. June 1998 l

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.- INDEX

. LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS l 1

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EAGI SECTION TABLE 3.3-3 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETP0lNTS . . . . . . . . . . . . . . . . . . . . .

3/43-19 TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS..........

3/4 3-21 3/4.3.3 MONITORING INSTRUMENTATION......................... 3/43-23 TABLE 3.3-4 RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS.........................................

3/43-24 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS SURVEILLANCE REQUIREMENTS...............

3/4 3-25

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Movabl e Incore Detectors . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 3-26

. Swimic Instrus ntetien............................ 3/4 3 TAOL 3.L : SCISMIC MONITORING IN';TRUMENTATION. . . . . . . . . . . . . . . . . 3/4 5-26 " '

A" 4ABLE 4.3-4 SEISMIC MONITORING IN';TRUMENTATION

---sVRVE4RANCE REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . .

3/4 3 2T U Meteorological Instrumentation. . . . . . . . . . . . . . . . . . . . . . 3/4 3-30 3/43-31 TABLE 3.3-6 METEOROLOGICAL MONITORING INSTRUMENTATION...........

TABLE 4.3-5 METEOROLOGICAL MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.......................... 3/4 3-32 Accident Monitoring Instrumentation................ 3/43-33 3/43-34 TABLE 3.3-7 ACCIDENT MONITORING INSTRUMENTATION................

TABLE 4.3-6 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.......................... 3/43-38 TABLE 3.3-8 DELETED Radioactive Liquid Effluent Monitoring Instrumentation.................................... 3/43-44 TABLE 3.3-9 RADIOACTIVE LIQUID EFFLUENT MONITORING 3/43-45 INST RUMENTAT ION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

TABLE 4.3-7 RADI0 ACTIVE LIQUID EFFLUENT MONITORING 3/43-47

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l INSTRUMENTATION SURVEILLANCE REQUIREMENTS..........

Radioactive Gaseous Effluent Monitoring Instrumentation.................................... 3/43-49 VI Amendment No. J45,179 HADDAM NECK eiss

r , . APR 2 61990 kSTRUMENTATION s

~ SE IC INSTRUMENTATION

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LIMIT CONDITION FOR OPERATION .

s seismic monitoring system instrumentation shown in 3.3-5 3.3.3.3 shall be OPE BLE.

APPLICABILITY: t all times.

ACTION: o L

'a. 'With the se mic monitoring system inopera e for more than 30 days, prepare nd submit a Special Repor to the Commission  !

pursuant to Spe ification 6.9.2 within A e next 10 days outlining j the cause of the a1 function and the lans for restoring the n

system to OPERABLE tatus. li The provisions of Spec ication .0.3 are not applicable, j b.

SURVEILLANCE REQUIREMENTS n stem shall be demonstrated 4

'4.3.3.3.1 The above seismic mo toring OPERABLE b'y the performance of he CHANNEL ECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL T T at the freque ies shown in Table 4.3-4.

4.3.3.3.2 The above re red seismic monitoring ystem actuated during a seismic event shall be stored to OPERABLE status ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a the seismic event.

CHANNEL CALIBRATION p formed within 10 days followi alyzed to determine Data shall be retri ed from actuated instruments and the magnitude of:t a vibratory ground motion. If it is etermined that the j

magnitude of the vent exceeded the Operating Basis' Earth ake, ionthen a pursuant to i Special Report all be prepared' and submitted to the Commi

.9.2 within'14 days describing the magnitude, equency Specification spectrum,' a resultant effect'upon facility features important o safety.

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3/4 3 27 Amendment No. 125 HADDAM NECK

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.r APR 2 61990

.,. TABLE 3.3-5 SEISMIC MONITORING INSTRUMENTATION MINIMUM INSTRU iTS INSTRUMENTS AND SENSOR LOCATIONS MEASUREMENT RANGE OPER&B E

1. Triaxial Serva A elerometer 0 to 0.59 (SSA-302) Basemat-Cihle Vad t
2. Digital Cassette Accelefs raph 5 Volts 1 (DCA-300)**
3. Response Spectrum Analyzer 5V s I (RSA-50)**
4. Playback System 5 Volts 1 (SMR-102)**
5. Seismic Warning Panel N/A 1 (SWP-300)**
    • All located in e Control Room s

f/]/S /MGE f/V16WII#NA'l!

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i HADDAM NECK 3/4 3-28 Amendment No. 125

APR 2 61990 TABLE 4.3-4

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$E'ISMIC MONITORING INSTRUMENTATION SURVEILLANCE RE0VIREMENTS ALOG CHANNEL l CHANNEL CHANNEL OPERATIONAL l N_ LOCATIONS INSTRUMENTS AND SENS QiL(E CAllBRATI 4 TEST ometer SA

1. Triaxial Servo Accel M R I

(SSA-302) Basemat-Cable ault

2. Digital Cassette Accelerogr h M R SA i (DCA-300)**

Response Spectrum Analyzer R SA 3.

(RSA-50)**

4. Playback System M R SA l (SMR-102)**

Seismic Warning Pa M R SA 5.

(SWP-300)**

    • All lo d in the Control Room

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N 178s/ AGE 1

I MADDAM NECK 3/4 3-29 Amendment No. 125

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FEBRUARY 1, 1995

,- INSTRUMENTATION BASES 3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 ~ RADIATION MONITORING FOR PLANT OPERATIONS The OPERABILITY of the Containment Atmosphere Gaseous Radioactivity Monitor-ing System ensures that Gaseous Radioactivity Monitoring System will monitor inside containment as a means to detect RCS leakage.

p -3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the core. The. OPERABILITY of this' system is demonstrated by irradiating

-each detector used and determining the acceptability of its voltage curve.

3 /4.3.3.1/ SEI SMIC INSTRUMENT ATION The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to determine the magnitude of a seismic event and evaluate the response of those features important tocsafety. This capabili-ty is required to permit comparison of the measured response to that used in the design basis for the facilit h J/4.3.3.4 METEOROLOGICAL INSTRUMENTATION The OPERABILITY of the meteorological instrumentation ensures that suffi-cient meteorological data is available for estimating potential radiation doses to the public as a result' of routine or accidental release of radio-active materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public and is consistent with the recommendations of Regulatory Guide 1.23, ~ "Onsite Meteorological Programs," February 1972.

3/4.3.3.5 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of ~ the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is Revision 3,

' consistent with the recommendations of Regulatory Guide 1.97,

" Instrumentation. for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," May 1983 and NUREG-0737,

" Clarification of TMI Action Plan Requirements," November 1980.

3/4.3.3.6 - DELETED B 3/4 3-2 Amendment No. M )79 HADDAM NECK esse

Docket No. 50-213

( CY-98-084 l

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Attachment 2 Haddam Neck Plant Proposed Revision To The Technical Specifications  ;

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INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE TABLE 3.3-3 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS...... ......... ... 3/4 3-19 TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS. ........ 3/4 3-21 3/4.3.3 MONITORING INSTRUMENTS 1 ION..... .... .......... ... 3/4 3-23 TABLE 3.3-4 RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS.... .................................... 3/4 3-24 TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS SURVEILLANCE REQUIREMENTS........ ...... 3/4 3-25 Movable Incore Detectors..... ......... ... ... . 3/4 3-26 TABLE 3.3-5 DELETED TABLR 4.3-4 DELETED i Meteurlogical Instrumentation......... ...... ..... 3/4 3-30 TABLE 3,3-6 METEOROLOGICAL MONITORING INSTRUMENTATION........... 3/4 3-31 TABLE 4.3-5 METEOROLOGICAL MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS........ .......... . . . 3/4 3-32 Accident Monitoring Instrumentation................ 3/4 3-33 TABLE 3.3-7 ACCIDENT MONITORING INSTRUMENTATION.... .. ....... 3/4 3-34 TABLE 4.3-6 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.... .. ... . .. ..... 3/4 3-38 TABLE 3.3-8 DELETED Radioactive Liquid Effluent Monitoring Instrumentation......... . ... .................. 3/4 3-44 TABLE 3.3-9 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION... .............. ............ .... 3/4 3-45 TABLE 4.3-7 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.......... 3/4 3-47 Radioactive Gaseous Effluent Monitoring Instrumentation............. .... ............. ... 3/4 3-49 HADDAM NECK VI Amendment No.225 , ///

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! HADDAM NECK 3/4 3-27 Amendment No. 436 I

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THIS PAGE INTENTIONALLY BLANK HADDAM NECK 3/4 3-28 Amendment No. 1-26

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1 HADDAM NECK 3/4 3-29 Amendment No. 126 L__-__-

INSTRUMENTATION BASES 3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING FOR PLANT OPERATIONS The OPERABILITY of the Containment Atmosphere Gaseous Radioactivity Monitor-ing System ensures that easeous Radioactivity Monitoring System will monitor inside containment as a means to detect RCS leakage.

3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage curve.

3/4.3.3.3 DELETED 3/4.3.3.4 METEOROLOGICAL INSTRUMENTATION The OPERABILITY of the meteorological instrumentation ensures that suffi-cient meteorological data is available for estimating potential radiation doses to the public as a result of routine or accidental release of radio-active materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public and is consistent with the recommendations of Regulatory Guide 1.23, "Onsite Meteorological Programs," February 1972.

3/4.3.3.5 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 2,

" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," May 1983 and NUREG-0737,

" Clarification of TMI Action Plan Requirements," November 1980.

3/4.3.3.6 DELETED HADDAM NECK B3/4 3-2 Amendment No.125 , 149

Docket No. 50-213 CY-98-084 t

l Attachment 3 Haddam Neck Plant Proposed Revision To The Technical Specifications Description Of Changes I

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,. U. S. Nuclur Regulatory Commission l

CY-98-084/ Attachment 3/Page 1 Description of Chance l The proposed change will delete Technical Specification 3.3.3.3, " Seismic Instrumentation"in accordance with the guidance contained in Generic Letter 95-10'. In accordance with the Generic Letter this material will be deleted from the Technical 3 Specifications and is being transferred to the Technical Requirements Manual (TRM). i The TRM is a document that is controlled by CYAPCO procedures. Any change to the I TRM requires that a review be conducted in accord >nce with the requirements of 10CFR50.59. This material will be relocated verbatim to the TRM with the exception of section, table and reference numbers, the correction of a typographical error discussed

' below, updating to reflect the new equipment, and to account for formatting differences.

l- The following information will be transferred to the TRM:

-3/4.3.3.3 SEISMIC INSTRUMENTATION TABLE 3.3-5 SEISMIC MONITORING INSTRUMENTATION TABLE 4.3-4 SEISMIC MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS

'In October 1997, it was concluded that in Technical Specification Table 3.3-5, the I Triaxial Servo Accelerometer (SSA-302) located on the basemat in the Cable Vault which had a measurement value of "O to 0.59" with no units associated with the values was incorrect. An evaluation established that per the vendor (Terra Technology)-

manual the correct range is 0.5g. Thus, this appears to be a typographical error, where the "g" was interpreted to be a "9" (i.e., 0.5g vs. 0.59). Therefore, in transferring Table 3.3-5 to the TRM, "O to 0.59" will be changed to " 0.5g".

In addition, CYAPCO will update the tables in the TRM to reflect the new seismic

. monitoring instrumentation once the transfer is complete.

l The use of the TRM to control material which has been relocated from the Technical 2

Specifications has been previously authorized by the NRC . . Currently the Haddam Neck Plant maintains, among other topics, information on fire protection, which has (1) . NRC Generic Letter 95-10, " Relocation of Selected Technical Specifications  ;

Requirements Related to Instrumentation," dated December 15,1995.

'(2) J. W. Andersen letter to J. F. Opeka, " Issuance of Amendment j (TAC No. M86247)," dated October 12,1993.

.(3) V. L. Rooney letter to J. F. Opeka, " Issuance of Amendment (TAC No. M84264),"

dated October 25,1995.

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. U. S. Nuclear Regulatory Commission

, CY-98-084/ Attachment 3/Page 2 been relocated from the Technical Specifications, into the Haddam Neck Plant's TRM.

The NRC has reviewed our control of the fire protection program using the TRM in inspection Report 95-09 and has found it to be acceptable.

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Docket Nos. 50-213 CY-98-084 l

l Attachment 4 Haddam Neck Plant Proposed Revision To The Technical Specifications Safety Assessment And No Significant Hazards Consideration June 1998 l

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l'. U. S. Nucl:ar Regulatory Commission

/' CY-98-084/ Attachment 4/Page 1 L

Haddam Neck Plant Proposed Revision To The Technical Specifications Safety Assessment And No Significant Hazards Consideration Safety Assessment l

The plant has permanently ceased operations, the reactor has been permanently i defueled, and the spent fuel is stored in the spent fuel pool.

Section Vl(a)(3) of Appendix A to 10CFR100 requires that seismic monitoring l instrumentation be provided to promptly determine the response of those nuclear power plant features important to safety in the event of an earthquake. This capability is required to allow for a comparison of the measured response to that used in the design basis for the unit. Comparison of such data is needed to (1) determine whether the L plant can continue to be operated safely and (2) permit such timely action as may be appropriate. However, seismic instrumentation does not actuate any protective equipment or serve any direct role in the mitigation of an accident.

L The capability of the plant to withstand a seismic event or other design basis accident is determined by the design and construction of systems, structures, and components.

The instrumentation is used to alert operators to the seismic event and evaluate the plant response. The NRC's Final Policy Statement on Technical Specification improvements (SECY-93-067) stated that instrumentation to detect precursors to

, ' reactor coolant pressure boundary leakage, such as seismic instrumentation, is not i included in the first criterion. As discussed above, the seismic instrumentation does not serve as a protective design feature or part of a primary success path for events which

challenge fission product barriers. The NRC staff, in Generic Letter 95-10, has

( concluded that the seismic monitoring instrumentation does not satisfy the 10CFR50.36

' criteria and need not be included in the technical specifications.

i f This material is being transferred to the Technical Requirements Manual (TRM). This transfer, is 'in accordance with Generic Letter 95-10m and is consistent with the Standard Technical Specifications for Westinghouse Plants (WOG STS) provided in

o. NUREG-1431.(2) The relocation of this information to the TRM will continue to provide adequate control over this equipment to ensure its continued opere aility.

(1)- NRC Generic Letter 95-10, " Relocation of Selected Technical Specifications Requirements Related to Instrumentation," dated December 15,1995.

'(2) NUREG-1451,'" Standard Technical Specifications, Westinghouse Plants, Specifications," Office of Nuclear Reactor Regulation, NRC, Volume 1, Revision 1, dated April 1995.

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. U. S. Nucl:ar Regulatory Commission CY-98-084/ Attachment 4/Page 2 In summary, the changes do not have an effect on the safety of the plant. These l changes will result in the relocation to the TRM of the seismic monitoring technical specification, modified to address the new section, table, reference numbers and equipment, the correction of a typographical error, and to account for formatting differences. Thus no..s of the above changes affect plant configuration nor do they affect plant operations. Therefore, the changes do not affect the safety of the plant.

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> U. S. Nucle:r Regulatory Commission CY-98-084/ Attachment 4/Page 3 Significant Hazards Consideration CYAPCO has reviewed the proposed changes to the Technical Specifications in accordance with 10CFR50.92 and concluded that the changes do not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve

. an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences "f an accident l previously evaluated.

As a result of the present plant configuration which has the fuel permanently l removed from the reactor, the reactor-related accidents previously evaluated (i.e., LOCA, MSLB, etc.) are no longer possible. The accidents previously evaluated that are still applicable to the plant are fuel handling accidents and L gaseous and liquid radioactive releases.

l . There is no significant increase in the probability of a fuel handling accident since

! refueling operations have ceased. In fact, there is a decrease in probability of a fuel handling accident since the need to move / rearrange fuel assemblies is minimal until they are removed from the spent fuel pool (i.e., for dry cask storage or for transferring to USDOE possession). In addition, the consequences of a fuel handling accident are continuing to decrease since the fuel in the spent fuel poolis continuing to decay.

The radiological consequences of a gaseous or liquid radioactive release are bounded by the fuel handling accident during defueled operation and a spent l resin fire during the reactor coolant system decontamination. With the plant defueled and permanently shutdown, the demands.on the radwaste systems are

. lessened since no new radioisotopes are being' generated by irradiation or-fission. - Therefore, there is no increase in the probability or consequences of a gaseous or liquid radioactive release. .

The ability of the plant to withstand a seismic event is not affected by this proposed change. The seismic instrumentation does not actuate any protective

- equipment or serve any direct role in the mitigation of an accident. The equipment will continue to be adequately controlled by the TRM to ensure operability and alert operators to a seismic event, should one occur, so that appropriate actions can be taken. Therefore, there is no increase in the l consequences of a seismic event.

t-This material is being transferred to the TRM. This transfet is in accordance with I: - Generic Letter 95-10W and is consistent with the WOG STS provided in 1 NUREG-1431.* .The removed material included in this category is Technical  :

Specification 3/4.3.3.3 and the related tables.

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e U. S. Nuclear Regulatory Ocmmission CY-98-084/ Attachment 4/Page 4 Based on the above, the proposed changes to the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

There is no change in how spent fuel is stored or moved in the spent fuel pool.

Therefore, the postulated fuel handling accidents are still bounding and are still considered as credible postulated accidents.

1 There is no change in the design and construction of plant systems, structures and components with respect to the capability to withstand a seismic event.

Therefore, the currently assumed radioactive releases are still bounding.

This material is being transferred to the TRM. This transfer is in accordance with 0 3 Generic Letter 95-10 ) and is consistent with the WOG STS provideJ in NUREG-1431.(2) The removed material included in this category are Technical Specification 3/4.3.3.3 and the related tables.

Based on the above, the proposed changes to the Technical Specifications do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of safety.

The capability of the plant to withstand a seismic event or other design basis accident is determined by the design and construction of systems, structures, and components. The instrumentation is used to alert operators to the seismic event and evaluate the plant response. The NRC's Final Policy Statement on Technical Specification improvement (SECY-93-067) stated that instrumentation to detect precursors to reactor coolant pressure boundary leakage, such as seismic instrumentation, is not included in the first criterion. As discussed above, the seismic instrumentation does not serve as a protective design feature or part of a primary success path for events which challenge fission product barriers. The NRC staff, in Generic Letter 95-10, has concluded that the seismic monitoring instrumentation does not satisfy the 10CFR50.36 criteria and need not be included in the technical specifications.

This material is being transferred to the TRM. This transfer is in accordance with 0

Generic Letter 95-10 ) and is consistent with the WOG STS provided in NUREG-1431.(2) The removed material included in this category are Technical Specification 3/4.3.3.3.

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. U. S. Nucl2ar Regulatory Commission

!' CY-98-084/ Attachment 4/Page 5 i

. The proposed changes to the Technical Specifications do not involve a significant reduction in a margin of safety due to the fact that the capability of the plant to withstand a seismic event or other design bases accident is not affected by this proposed change.

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