NPL-97-0804, Forwards Response to Request for Addl Info Re TS Change Requests for Radiation Monitoring Sys,Radiological Effluent Tech Specs,Health Physics Manager Qualification & Radiation Protection Program
| ML20203K291 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/15/1997 |
| From: | Dante Johnson WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20203K296 | List: |
| References | |
| NPL-97-0804, NPL-97-804, NUDOCS 9712220292 | |
| Download: ML20203K291 (15) | |
Text
. - . . _ _ . _ _
Wisconsin Electnc POWER COMPANY i Point Beoch Nuclear Nant (920) 75$ 2321 6610 Nuclear Rd., Two Rivers, WI 54241
- NPL 97-0804 10CFR50.90 December 15,1997 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station PI-137 Washington, DC 20555 Ladies / Gentlemen:
DOCKETS 50-266 AND 50-1Q1 BESEDESE TO REO_UEST FOR ADDITIONAL INFORMATION IECHNICAL SPECIFICATION CHANGE REOUESTS RELATING TO RADIATION PROTECTION. DATED AUGUST 15.1997 P_OINT BEA("I NUCLEAR PLANT. UNITS 1 AND 2 By letter dated August 15,1997, Wisconsin Electric Power Company received a request for edditional information (RAI) pertaining to Technical Specifications change requests (TSCRs) 172,174,182, and 195.
These TSCRs involve proposed changes to the Point Beach Nuclear Plant Technical Specifications for radiation monitoring system, radiological effluent Tech'tical Specifications, Health Physics manager qualification, and radStion protection program.
Our response to the questions contained in the request for additional information aie contained in Attachment I to this letter. Additionally, related revisions to TSCRs 172,174,182, and 195 and a copy of the RAI are provided in Attachments 2,3,4, and 5 to this letter.
If you have any questions or require additional information, please contact us.
, Sincerely, Douglas F. Johnson Subscribed and sworn before me on Manager, this M day of /Aru Ao / 1997.
Regulatory Sersices and Licensing (L db M , M 1 w f_d Attachments Notary Pu61ic, State of Wisconsin !
- My commission expires Sfptsmbfr 16. 2001 {
cc: NRC Regional Administrator 4 ,
NRC Resident inspector dA '
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- Attachment te NPL 97-0804
. Page 1 of 8i m
t ATTACIIMENT 1 RESPONSES TO QUESTIONS -
~ Technical Specifications Change Request 172-Question;
.1. It is the NRC's understanding that PBNP has three categories of monitors in the rc'liation monitoring system: Area monitors, effluent monitors and process monitors. Please verify the lists of radiation monitors in Attachment B, Tables 1. 2, and 3 include all radiation monitors in the radiation monitoring system.
' Response:
'In gener-!, as described in Section i1.2.3 of the PBNP FSAR, radiation monitors are typically in one of two main categories: Area and process (process monitors include efiluent monitors). Area manitors provide direct indication of area radiation dose rates in various areas of the plant.
Process monitors track radiation levels involved with some process such as the flow of effluent in a line or the amount of radioactivity in a tank. A third category of monitor listed in Chapter 11 of the PBNP FS AR is the SPING (System-level Particulate, Iodine, and Noble Gas). These are process mor.Pors for the containment purge exhaust vent, auxiliary building exhaust vent, and the drumming area exhaust vent.
Tables 1,2, and 3 of Attachment B to the RAI have been reviewed. The following recommended
- corrections have been identified for Attachment B.
In Table 2, RMS Process Monitors, page B-4 of the RAI lists the RMS monitor RE-238 but provides the' description for the RE-241 monitor. Change the current RE-238 listing into two
- different monitors as indicated below:-
. RE-238 TSC noble gas monitor, monitors nobic .2s activity of the TSC air supply RE-24 I; SBCC iodme monitor, monitors iodme in SBCC air supply Several RMS monitors listed in Table 3 of the RAI have beer. Jeleted from the system (see PBNP FS AR Table 11.2-8,' SPfNGs). None of the deleted monitors had a required ccr rol function or were relied on for release quantification. The deleted monitors are the following:
. l(2)RE-302, the containment purge exhaust alpha particulate monitors.
. l(2)RE-308, the containment purge exhaust low range gas background monitors, RE-312,' auxiliaiy buildmg exhaust alpha particulate monitor,
' RE 318, auxiliary buildmg exhaust low range gas monitor background, RE 322, dmmming area exhaust alpha particulate monitor, RE-328, drumming area exhaust low range gas background monitor.
Attachment to NPL 97-0804 Page 2 of 8 Question:
. 2. In each category, some of the monitors, listed in Attachment B, Table 4, have control functions that may meet the requirements of 10 CFR 50.36. Please address those monitors listed in Attachment B. Tables 1,2,3, and 4 which have control functions and provide additional information why these monitors do/do not meet any of the criteria of 10 CFR 50.36.
Response
The list of monitors m the RAI Table 4 is consistent with the iBNP FSAR Section 11.2 descriptions of the radiation monitors that have control functions, except the FSAR does not list the control functions associated with SPING 21 and 22, the Unit 1 and Unit 2 containment purge exhaust. Further, the RAI Table 4 lists 1(2)RE-305 as the only monitor in the purge exhaust system as the initiator of containment ventilation isolation (CVI). Actually,1(2)RE-301 Beta
- Particulate,1(2)lE-303 lodine,1(2)RE-305 Low-range Gas,1(2)RE-306 Area Monitor,1(2)RE-307 Mid-range Gas, and 1(2)RE-309 H!gh-range Gas, which are collectively referred to as SPIN 3-21 and SPING 22 also initiate CV1 for the respective unit. Only 1(2)RE-305 is required to initiate the isolation function.
RE-101 Control Room Area Monitor and IG-235 Control Room Noble Gas - Shift control room ventilation to Mode 4, outside air filtration (not Mode 3 as stated in RAI Table 4). These monitors are considered part of the control room emergency filtration system for the purposes of meeting system operability requirements. The applicable LCO is PBNP Technical Specification 15.3,12 and the applicable surveillance requirement is contained in PBNP Technical Specification 15.4.11. Dr. sed on their accident mitigation function for control room ventilation, these monitors could be considered as required to be covered in the Technical Specifications under the provisions of 10 CFR 50.36, Criterion 3. During the review of these monitors for this RAI, it was discovered that the alarm response book entries for these monitors continue to reference an outdated analysis that uncluded tilat these monitors are not necessary for control room emergency tiltration operation. The applicable radiation monitoring system alann response book entries will be revised to correct this discrepancy.
l(2)RE-212 Containment Noble Gas and 1(2)RE-305 Containment Purge Exhaust Low Range Gas - Initiates CVI. These monitors are considered part of the containment purge and vent system isolation for the purposes of meeting system operability requirements. The applicable LCO and surveillance requirements a e contained in PBNP Technical Specification 15.3.8,
" Refueling." CVI in response to high radiation input signals is not a required function for any PBNP accident analyses. Therefore, the control function of these monitors does not meet any of the four criteria contained in 10 CFR 50.36. The applicable PBNP design basis accident analysis is described in PBNP FSAR Section 14.2.1 " Fuel Handling Accidents."
The FSAR states on pages 14.2.1-6 and 7,"The noble gas activity could be released either in the containment or in the auxiliary (fuel storage) building. The whole body dose to personnel
Attachment to NPL 97-0804 Page 3 of 8 tin the containment, were they to remain in this accident area, would be 4.8 rem, or to personnel in the fuel storage building, were they to remain ~in this accident a ea, would be 4.0
, rem. Each dose is calculated on the basis of the respective area ventilation rates,25,000 and 21,000 cfm, and 0.5 rem /MPC (Xe 133); Both area ventilation systems are in operation under administrative control during refueling. However, radioactivity monitors woulc'
- immediately indicate and alarm the increased activity levels, directing evacuation of the
- respective area. Activity in the containment would automatically close the purge ducts." The off-site dose analyses described in FSAR Section 14.2.1 do not require the operation of purge
- exhaust isolation or CVI because the fuel handling accident is analyzed as an unobstructed,;
ground level release.
RE 214 Auxiliary Building Vent Exhaust Gas Monitor - Shifts Auxiliary Building Ventilation to the Carbon Filters Shuts Gas Release Valve RCV-014, if Open. This cantrol function is provided to assist in prevention of efnuent release in excess of 10 CFR 20 limits.- The applicable accident analysis contained in FSAR Section 14.2.3 " Accidental Release Waste Gas" does not require this control function to operate because the dose analysis is based on
. release with,ut isolation. Additionally, automatic operation of this system is currently not required for mitigation of any accident for PBNP. Therefore, this function does not meet any
- of the four criteria contained in 10 CFR 50.36.
RE 217 Component Cooling Water Liquid Monitor - Shuts Component Cooling Surge Tank Vent Valve RCV 017. The CCW surge tank vent valve is normally maintained in a closed position. If RCV-017 is open, its position is controlled administratively. Therefore, this control function is no longer required (Reference Licensee Event Report 92-009 01,
" Component Cooling Water System Surge Tank Vent Valves Outside Design Basis," dated May 17,1993). Therefore, this function does not meet any of the four criteria contained in ,
RE 218 Waste Disposal System Liquid Monitor - Shuts Waste Liquid Overboard Valve RCV-018; This control function is provided to prevent accidental release of waste liquid as described in FSAR Section 14.2.2 " Accidental Release-Recycle or Waste Liquid."
Therefore, this function meets Criterion 3 of 10 CFR 50.36 and will be be added to . 2 Technical Specifications.
1(2)RE 219 Steam Generator Blowdown Sample Line Monitor - Shuts Blowdown Valves (MS-5958 and MS 5959), Blowdown Tank Outlet Valve (MS-2040), and Blowdown Sample Isolations (MS-2083 and 2084). This control function is provided to assist in prevention of efnuent release in excess of 10 CFR 20 limits. This function is not utilized for accident mitigation. This function does not meet any of the four criteria contained in 10 CFR 50.36, 1(2)RE-222 Steam Generator Blowdown Sample Line Monitor - Shuts Blowdown Valves (MS-5958 and MS-5959) and Blowdown Tank Outlet Valve (MS-2040). This control function is provided to assist in prevention of effluent release in excess of 10 CFR 20 limits. This function is not utilized for accident mitigation. This function'does not meet any of the for r criteria contained in 10 CFR 50.3f
Att: chm:nt to NPL 97 0804 Page 4 of 8 RE-223 Waste Distillate Tank Overboard Monitor - Shuts Waste Distillate Overboard Valve FCV-LW-15. This control function is provided to prevent accidental release of waste liquid as described in FS AR Section 14.2.2 " Accidental Release-Recycle or Waste Liquid." Therefore, this function meets Criterion 3 of 10 CFR 50.36 and will be be added to the Technical Specifications.
Question:
- 3. Please provide information on other radiation monitors, identified by item 1, that meet the criteria of 10 CFR 50.36. Providejustification on why these monitors, if any, are not included in the technical specifications (TS).
Response
NUREG-1431, " Standard Technical Specifications - Westinghouse Plants," contains standard guidance for meeting the criteria of 10 CFR 50.36. Some NUREG 1431 sections that may be pertinent are listed in Attachment A of the RAI. The NUREG-1431 sections listed in Attachment A of the RAI for possible radiation monitoring requirements for the PBNP monitors, identifia by item 1, are reviewed as follows:
TS 3.3.3 Post-accident Monitoring (PAM) instrumentation.
Containment high range radiation monitors and the main steam line monitors are the only applicable instruments. Containment high range radiation are PBNP monitor channels RE-126, RE-127, and RE-128. The main steam line radiation are monitor channels 1(2)RE-231 and 1(2)RE-232. These channels are already included in PBNP TS Table 15.3.5-5. The surveillance requirement for the containmer t high radiation monitors is contained in TS Table 15,4.1-1, item 25. TSCR 172 proposes to specifically include the main steam line monitors in TS Table 15.4.1-1, item 36.
TS 3.3.5 Containment Ventilation Isolation Instrumentation As stated in the answer to question 2, CVI in response to high radiation input signals is not a required function for any PBNP accident aaalyses, in particular the fuel handling accident.
The LCO and Surveillance requirement for this function are contained in PBNP TS 15.3.8.
Based on this function not being required to meet any 10 CFR 50.36 criteria, removal of these requirements from the PBNP Technical Specifications may be warranted. No Technical Specifications changes are being proposed for this function, at this time.
TS 3.3.6 Control Room Emergency Air Treatment System Actuation Instrumentation As stated in the answer to question 2, these monitors are considered part of the control room emergency filtration system for the purposes of meeting system operability requirements. The applicable LCO is PBNP Technical Specification 15.3.12 and the applicable surveillance requirement is contained in PBNP Technical Specification 15.4.11. These monitors could be
Attachment to NPL 97-0804 Page 5 of 8 considered as required to be covered in the Technical Specifications under the provisions of 10 CFR 50.36, Criterion 3. Proposed Technical Specifications changes are provided in Attachment 2.
TS 3.4.15 RCS Leakage Detection Instrumentation Technical Specification 15.3.1.D.7 establishes the LCO requirements for RCS leakage detection in the current Technical Specifications for PBNP.
TS 3.7.7 Component Cooling Water System As stated in the answer to question 2, the CCW surge tank vent valve is nomially maintaineo in a closed position. Therefore, this control function is no longer required (Reference Licensee Event Report 92-009-01," Component Cooling Water System Surge Tank Vent Valves Outside Design Basis," dated hiay 17,1993). Therefore, this function does not meet any of the four criteria contained in 10 CFR 50.36.
TS 3.7.8 Service Water System As stated in the answer to question 2, RE-218 and RE-223 are the monitors that provide control input to shut valves that prevent accidental release of waste liquid as described in PBNP FSAR Section 14.2.2 " Accidental Release-Recycle or Waste Liquid." Therefore, these monitors should be included in the Technical Specifications. These are not service water system components. The radiation monitors, RE-218 and RE-223, are designated in the radiation monitoring system (RhtS). The associated valves, Waste Liquid Overboard Valve RCV-OlS and Waste Distillate Overboard Valve FCV-LW-15, are designated waste liquid (WL) and blowdown evaporator (BE) systems, respectively.
TS 3.7.9 Control Room Emergency Air Treatment System (Note: NUREG-1431 reference should be TS 3.7.10 control room emergency filtration system)
As stated in the answer to question 2, RE-101 Control Room Area hionitor and RE 235 ,
Control Room Noble Gas - Shift control room ventilation to hiode 4, outside air filtration (not hiode 3 as stated in RAI Table 4). These monitors are considered part of the control room emergency filtration system for the purposes of meeting system operability requirements. The spplicable LCO is PBNP Technical Specification 15.3.12 and the applicable surveillance requirement is contained in PBNP Technical Specification 15.4.11.
These monitors could be considered as required to be covered in the Technical Specifications under the provisions of 10 CFR 50.36, Criterion 3. Proposed Technical Specifications changes are provided in Attachment 2.
i Attachment to NPL 97-0804 Page 6 of 8 TS 3.7.10 Auxiliary Building Ventilation System (Note: NUREG-1431 reference should be TS 3.7.12 Emergency Core Cooling System Pump Room Exhaust Cleanup System) ,
1 As stated in the answer to question 2, RE-214 Auxiliary Building Vent Exhaust Gas Monitor -
Shins Auxilia y Building Ventilation to the Carbon Filters Shuts Gas Release Valve RCV-014, if Open. This control function is provided to assist in prevention of effluent release in excess j of 10 CFR 20 limits. The applicable accident analysis contained in FSAR Section 14.2.3
" Accidental Release-Waste Gas" does not require this control function to operate.
Additional!y, automatic operation of this system is currently not required for mitigation of any ;
accident for PBNP. Therefore, this function does not meet any of the four criteria contained in 10 CFR 50.36.
Question:
- 4. Submit the appropriate TS changes, in accordance with 50.36, ror those radiation monitors that should/must remain in (S. Include limiting conditions for operation, applicability, action statements with condLns, required action and completion time speci0ed, surveillance requirements, surveillance frequencies, required number of monitors, monitor setpoints, and bases.
Response
Based on the responses to the preceding three questions, the following modifications to Technical Specifications change request 172 are appropriate:
- In Table 15.4.1-1 under item 36, include RE-218 and RE 223. A new note for check of these channels will require a source check to be performed prior to initiation of a release using the associated discharge flowpath. Failure of the source check surveillance effectively prevents use of the discharge flowpath. A shifily channel check will continue for the duration of the release. The setpoints for these channels are controlled by the Radiological Efiluent Control Program, which is a licensee controlled program as described in TSCR 174 A refueling calibration will be maintained and quaterly channel functional testing will be performed.
These surveillance requirements are applicable during all plant conditions.
As stated in the answer to question 2, RE-101 Control Room Area Monitor and RE-235 Control Room Noble Gas - Shift control:oom ventilation to Mode 4, outside air filtration (not Mode 3 as stated in RAI Table 4). These monitors are considered part or the control room emergency filtration system for the purposes of meeting system operability requirements. The applicable LCO is PBNP Technical Specification 15.3.12 and the applicable surveillance requirement is contained in PBNP Technical Specification 15.4.11. These monitors could be considered as required to be covered in the Technical Specifications under the provisions of 10 CFR 50.36, Criterion 3. A license condition is currently in effect to require re-analysis of the control room to show that the dose limits ci GDC 19 can be met under all design basis accident conditions and submittal of a license amendment request by Febniary 27,1998. Additional Technical
o _ Attachment to NPL 97-0804 Page 7 of 8 Specifications requirements (clg. monitor setpoints) for the control room emergency filtration system as necessary to show compliance with that license condition will be submitted at that time.
Th modifications to TSCR 172 are provided as' Attachment 2.
Technical Specifications Change Request 174 Question:
~
- 5. New guidance (Attachment C) was provided to the Nuclear Energy Institute (NEI) on April 9, 1997, on TS for the radioactive efiluent controls program. This new guidance includes 10
_ CFR Part 20 changes. Please review the new guidance and revise your submittal as appropriate.
Response
- The modifications to TSCR 174 are provided as Attachment 3.
Question:
- 6. Revise submittal to remove only those radiological emuent monitors that do not meet the requirements of 10 CFR 50.36.
Response
'As stated in the answer to question 4, appropriate Technical Specification requirements for RE-218 and RE-223 are being proposed in Attachment 2. The application of the 10 CFR 50.36 criteria concluded that these monitors are necessary for accident response. The proposed Technical Specification requirements are for the control function of these instruments in the prevention of waste liquid release accidents, as described in the Point Beach FS AR section 14.2.2, No effluent monitors were identified by the application of the 10 CFR 50.36 criteria for inclusion
_in the Technical Specifications for purposes of their effluent monitoring function. It is still
- appropriate tc relocate all effluent monitors to the radiological effluent control program under the U guidance contained in GL 89-01 and GL 95-10.
Technical Specifications Change Request 182 Question:
~
' 7. Please provide suflicient information to describe the Health Physicist position description.
The description should document that the position is a professional, supervisor position that affords adequate authority and opportunity to represent program interests on a plant-wide -
' basis: Additionally, describe the involvement of the designated Health Physicist in the day-to-L day operation and oversight of the plant radiation protection program.
. _ . . . .. -- , . - . . . _ . . . . _ ~ . _ . . _ _ . _ . .y.. _ . . .
' Attachment to NPL 9/4804 L I
i Page 8 of.81
- Response
^-
The additional information is contained in Attachment 4l1 j
, ETschnical Specifications Chan'ge Request 195 -
.-I Question: .
a 3
~
- 8E New guidance (Attachment D)_was provided to NEI on April 9,1997, on TS administrative ;
. controls for a high radiation area This new guidance includes 10 CFR 20 changes,' Please = -- i n- review the new guidance and revise your submittal as appropriate.
' Response:
- The modifications to TSCR 195 are provided as Attachment 5.
Question:
- 9. - If you choose not to revise your submittal per the new guidance, please describe how your ,
program complies with the new Part 20 requirements for high radiation area with dose rates
- greater than 1.0 rem / hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation, but less than'500 rads / hour at I' meter from the radiation source or from any surface penetrated by the radiation. ,
^ Response:
-This question does not apply based on incorporation of new guidance, see Attachment 5.
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i Attachment to NPL 97-0804 Page1of3 ATTACHMENT 2 SUPPLEMENT TO TSCR 172 Technical Specifications change request (TSCR) 172, as described in letters from Wisconsin Electric to the Nuclear Regulatory Commission (NRC) dated May 2,1995, October 12,1995, and March 26,1996, proposes to change Technical Specifications surveillance requirements for the radiation monitoring system from monthly to quarterly and specify only the necessary monitors. In a letter dated August 15,1997, the NRC provided a request for additional information that included four questions pertaining to this Technical Specifications change request.
The following modifications to TSCR 172 were identified during the preparation of the response to the NRC's request for additional information:
- 1. Add RE 218 Waste Disposal System Liquid Monitor and RE-223 Waste Distillate Overboard Monitor to item 36 in TS Table 15.4.1-1. T;.ese monitors will use note (7) for the " Check" requirement, "R" as modified by note 14, is the refueling frequency for the " Calibration" requirement, and "Q" which is quarterly for the " Test" requirement. These monitors are needed for mitigation of the accident described in the PBNP FSAR section 14.2.2, 1
" Accidental Release-Recycle or Waste Liquid."
- 2. Change note (7)in TS Table 15.4.1-1 to state, " Source check is required prior to initiation of a release. Source check is an assessment of channel response by exposing the detector to a source ofincreased radiation. Channel check is required shiftly during a release. If monitor or isolation function is discovered inoperable discontinue release immediately." This note will be applied to the check column for the RE-218 Waste Disposal System Liquid Monitor and RE-223 Waste Distillate Overboard Monitor. The proposed surveillance requirements for these channels are appropriate because the source check will verify the operability of the channel prior to a release and the quarterly functional test requirement will verify operability of the isolation function. The shiftly channel check will continue to be used to observe for obvious abnormalities that could affect channel operability while the release is in progress.
The statement to require that the release discontinue immediately will ensure that proper action is taken if the function beco nes inoperable.
The revised edited Technical Specification pages for TSCR 172 are attached. The "No Significant Hazards Consideration," provided with the original submittal of TSCR 172 via letter dated May 2,1995, has been reviewed. The conclusion that the proposed Technical Specifications changes do not pose a significant hazard remains valid, although the evaluation has been revised as follows:
In accordance with the requirements of 10 CFR 50.91(a), Wisconsin Electric Power Company (Licensee) has evaluated the proposed changes against the standards of 10 CFR 50.92 and has determined that the operation of Point Beach Nuclear Plant, Units 1 and 2 in accordance with the
. _= _ _ ___
Attachment to NPL 97-0804-Page 2 of 3 proposed amendments does not present a significant hazard. The analysis of the requirements of ,
10 CFR 50.92 and the basis for this conclusion are as follows:
- 1. Operation of this facility under the proposed Technical Specifications will not create a
- significant increase in the probability or consequences of an accident previously evaluated.
The probabilities of accidents previously evaluated are based on the probability of initiating events for these accidents. Initiating events for accidents previously evaluated for Point Beach include: Control rod withdrawal and drop, CVCS malfunction (Boron Dilution), startup of an inactive reactor coolant loop, reduction in feedweter enthalpy, excessive load increase, losses of reactor coolant flow, loss of external electrical load, loss of normal feedwater, loss of all AC power to the auxiliaries, turbine overspeed, fuel handling accidents, accidental releases of waste liquid or gas, steam generator tube reure, steam pipe rupture, control rod ejection, and primary coolant system ruptures.
This liccr.2e amendment request proposes to change the surveillance requirements for the Point Beach Nuclear Plant Technical Specifications associated with the radiation monitoring system.
These proposed changes do not cause an increase in the probabilities of any accidents previously evaluated because these changes will not cause an increase in the probabuity of any initiating events for accidents previously eva!uated. In particular, these changes affect radiation monitcrs which do not cause accidents.
The consequences of the accidents previously evaluated in the PBNP FSAR are determined by the results of analyses that are based on initial conditions of the plant, the type of accident, transient response of the plant, and the operation and failure of equipment and systems. The changes proposed in this license amendment request provide appropriate surveillance requirements for the radiation monitoring system.
The proposed changes re Juce the burden associated with radiation monitoring system required surveillance by establishing surveillances for only the necessary monitors (i.e.
elimination of the testing requirement for monitors that do not perform a required function) and changing the testing frequencv for these monitors from monthly to quarterly.
The proposed changes do not increase the , aability of failure of this equipment or its ability to operate as required for the accidents previously evaluated in the PBNP FSAR.
Therefore, this proposed license amendment does not affect the consequences of any accident previously evaluated in the Point Beach Nuclear Plant FSAR, because the factors that are used to determine the consequences of accidents are not being changed
- 2. Operation of this facility un6r the proposed Technical Specifications change will not create the possibility of a new er different kind of accident from any accident previously evaluated.
~ Attachment to NPL 97-0804 '
Page 3 of 3 New or different kinds of accidents can only be created by new or different accident' initiators or sequences. New and different types of accidents (different from those that were originally analyzed for Point Beach) have been evaluated and incorporated into the licensing basis for Point Beach Nuclear Plant. Examples of different accidents that have been incorporated into the Point Beach Licensing basis include anticipated transients -
without scram and station blackout.
The changes proposed by this license amendment request do not create any new or different accident initiators or sequences because these changes to the surveise requirements for the radiation monitoring system will not cause failures of equipmea or accident sequences different than the accidents previously evaluated. Therefore, these proposed Technical Specification changes do not create the possibility of an accident of a
- different type than any previously evaluated in the Point Beach FSAR.
- 3. Operation of this facility under the proposed Technical Specifications change will not create a significant reduction in a margin of safety.
-The margins of safety for Poir.t Beach are based on the design and operation of the reactor and containment and the safety systems that provide their protection. The changes proposed by this license amendment request provide the appropriate surveillance requirements for the radiation monitoring system. The revised surveillance requirements will continue to ensure that the required radiation monitors will operate as required. The design and operation of the reactor and containment are not affected by these proposed changes. Therefore, the margins of safety for Point Beach are not being reduced because the design and operation of the reactor and containment are not being changed.
w
j* - I A TABLE 15.4.1-1 (continued)
PLANT CONDITIONS HQ, CilANNEL DESCRIPTION CllECK CALIBRATE IESI WilEN REOUIRED Auxiliary Feedwater Flowrate (13) R - ALL-20.
- 21. Boric Acid Control System - R - ALL Boric Acid Tank Level D R - ALL 22.
- 23. Charging Flow - R - ALL
- 24. Condensate Storage Tank Level S(l) R - ALL Containment liigh Range Radiation S(l) R(14) ALL
- 25. 44(4) Q@
- 26. Containment flydrogen Monitor D - -
ALL
-Gas Calibration -
Q(15) - ALL
-Electronic Calibration - R - ALL
- 27. Containment Pressure S. R Q(I,3,9) ALL
'2 8. Containment Water Level M R - ALL
- 29. Emergency Plan Radiation Survey Instruments Q R Q ALL
- 30. Environmental Monitors M - - ALL
- 31. In-Core Thermocouples M R(14) -
ALL
- 32. Low Temperature Oves piessure Protection Systen S(12) R (10) ALL'
- 33. PORV Block Valve Position Indicator Q R -
, ALL
- 34. PORV Operability -
R Q(1I) ALL
- 35. PORV Position Indicator S(21) R R ALL Unit 1 - Amendment No 172 Page'3 of 6 February 20,1997 Unit 2 - Amendment No.176
L TABLE.15.4.1-1 (continued)
. PLANT. CONDITIONS Y CHANNEL DESCRIPTION. CilECK CAL 10 RATE J1SI . WilEN REQUIRED
' 36. - Radiation. Monitoring System R E-lit WOS (J.g i. d ting. l.< -(7)'
h.id Q A t.L
~ 1T f-213 % b D;shllsic,'Over A ,1 A. :l.<- (7)- RJV) Q 4t L ALG
~
RE-2 31 k Sli., c-a; Rela.n r1,,nu 50) NI'Q @)
-. RE - u2. 8 ' Sla,, t:-alabaL:w 503 RbD 46h A'L 4
. 3 7. . Reactor Vessel Fluid Level System M R ,
ALL
- 38. Refueling Water Storage Tank Level -
R -
ALL
- 39. :
Residual lleat- Removal Pump Flow -
R -
'ALL
- 40. Safety Valve Position Indicator M R -
ALL
- 41. - Subcooling Margin Monitor M !
R --
ALL
- 42. Turbine'Overspeed Trips
-Independent Overspeed Protection System -
R M(1) ALL
-Overspeed Block trip -
R M(1) ALL
- 43. . Volume Control' Tar.k Level -
R -
ALL
- 44. Reactor Protection System and - -
M(1,23) ALL _
Emergency Safety Feature Actuation-System Logic Reactor Trip System Interlocks
- 45. .
-Intermediate Range Neutron Flux, P-6 -
R(24) R ALL
-Power Range: Neutron Flux, P-8 -
R(24) R. ALL '
-Power Range Neutron Flux, P-9 -
R(24) R ALL
-Power Range Neutron Flux,'P-10 -
R(24) R ALL
-1st Stage Turbine Impulse Pressure -
R(24) R ALL 8-
~ Unit L- Amendment No. ' 157 Page %nf 6-December.8 4 ,
Unit j Amendment No. 161 , ,
i ".; , e ,
( .
tiOTATION USED IN TABLE 15.4.1-1
-S-'Each shift
-D- Daily
--W- W:::kly .
Q- Quarterly M- Monthly P- Pricr to reactor criticality if not performed during the previous week.
R-.Each refueling interval-(but not to exceed 18 months)
PWR- Power and Low Power Operation, as defincd in Specifications 15.1.h. and 15.1.n. -
IlGT S/D- Hot Shutdown, as defined in Specification 15.1.g.1..
COLD S/D- Cold Shutdown, as defined in Specification 15.1.g.2. '
REF S/D- Refueling Shutdown, as defined in Specification 15.1.g.3.
' ALL- All conditions of operation, as defined in Specifications 15.1.g, h and n. ,
NOTES USED IN TADtE 15.4.1-1 (1) Not required during periods of refueling shutdown, but must be performed prior to reactor criticality if it has not
, been-performed during the previous survelliance period. .
(2) Tests of the low power trip bistable setpoints which cannot be done during power operations shall be conducted I prior to reactor criticality if not done in the previous surveillance interval.
(3) Perform test of the isolation valve signal. ,
(4) Perform by means of the moveable 'incore detector system.
(5) Recalibrate if the absolute difference is 23 percent. .
(6) Verification of proper breaker alignment and thpt the 120 Vac instrument buses are energized.
(7) R ad iometive-Effl uen t-Honi to ri ng-Ins trumen t a tion-Surve H4 ence-Requ i remen tw ee-speel ff ed-i n-Section-1544.
i (8) Verify that the associated rod insertion limit is not being violated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> whenever the rod insertion limit alarm fnr a control bank is inopera51e.
(9)' Test of Narrow Range Pressure, 3.0 psig, -3.0 psig excluded.
Source check is required prior to initiation of a relcase. Source check is an assessment of channel response by exposing the detector to a source ofincreased radiation. Channel check is required shiftly during a release. If ruonitor or isolation function is discovered inoptrabic. discontinue release imnx:diately, bnit1-AmendmentNo. 157 Page 5 of 6 l
December 8, 1994:
Unit 2 - Amendment No. 161 k
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