NPL-98-0429, Provides Suppl to Tech Specs Change Request 172 & Response to Request for Addl Info for Point Beach Nuclear Plant,Units 1 & 2

Provides Suppl to Tech Specs Change Request 172 & Response to Request for Addl Info for Point Beach Nuclear Plant,Units 1 & 2

ML20248E932
Person / Time
Site:	Point Beach
Issue date:	05/27/1998
From:	Kaminskas V WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248E936	List: ML20248G167 NPL-98-0429, Provides Suppl to Tech Specs Change Request 172 & Response to Request for Addl Info for Point Beach Nuclear Plant,Units 1 & 2
References
GL-93-05, GL-93-5, NPL-98-0429, NPL-98-429, NUDOCS 9806040043
Download: ML20248E932 (16)

Text

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Wisconsin Electric POWER COMPANY f

Point Beoch Nuclear Plant (920) 755 2321 6610 Nuclear Rd., Two Rivers, WI 54241 NPL 98-0429 10 CFR 50.90 May 27,1998 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, DC 20555 Ladies / Gentlemen:

DOCKETS 50-266 AND 50-301 SUPPLEMENT TO TECHNICAL SPECIFICATIONS CHANGE REOUEST 172 AND RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION P_OINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 This letter provides additional information in support of Technical Specifications Change Request (TSCR) 172," Modifications to Technical Specifications Section 15.4.1, Operational Safety Review." TSCR 172 was submitted in a letter dated May 2,1995. Supplements to the TSCR 172 have been submitted in letters dated October 12,1995, March 26,1996 and J

December 15,1997.

Attachment I to this letter provides our response to a request for additional information dated April 29,1998. This letter also provides supplemental information for Technical Specifications Change Request 172 in Attachment 2. Specifically, we are proposing addition of control room and condenser air ejector iadiation monitor surveillance requirements and correct some errors in the notes of Table 15.4.1 1. We are also proposing to revise the surveillance requirements for i radiation monitoring instrumentation that does not have an associated trip or initiation function i and to use a monthly channel check for post-accident radiation monitors. The safety evaluation i of these changes is provided in Attachment 3. The edited Technical Specifications pages are prov;ded as Attachment 5 to this letter.

1 We have determined that these changes and corrections do not involve a significant hazards

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consideration, authorize a significant change in the types or total amounts of any effluent release, I or result in any significant increase in individual or cumulative occupational exposure. I l

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FPL 98-0429 May 27,1998 Page 2 Thereforh, we conclude that the proposed amendments meet the requirements of 10 CFR 51.22(c)(9) and that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared. The conclusions of the original "No Significant Hazards" determinations for operation under the proposed Technical Specifications -

remain applicable. The " Finding of No Significant Hazards Consideration"is provided as Attchment 4 to this letter.

- If you have any questions or require additional information, please contact us.

Sincerely,

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Vito A.Kammskas Subscribed and swom befojr me on Manager, this JM dayof W/u ~ .

1998.~

Regulatory Services & Licensing (

Attachments Npfary Pu6iic, State #of Wisconsin My commission expires September 16. 2001 cc: NRC Regional Administrator NRC Resident Inspector PSCW

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Attachment to NPL 98-0429 Page1of5 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Question:

1. The information included in Wisconsin Electric (WE) Power Company's December 15,1997, submittal, did not supply sufficient information to conclude that the control room radiation monitors RE-101 and RE-235 should not remain in TS Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests ofInstrument Channels." Verify that the current control room dose analysis does rely on shifting the control room ventilation to Mode 4 (outside air filtration) to meet the dose guidelines of General Design Criterion 19. It would seem that the performance ofchecks, calibrations, and testing is required to assure system operability between system functional tests. If the monitors are added, justify any changes you propose regarding the table entries if different from the RMS entries. Specifically, if WE plans to increase the testing to quarterly in accordance with Generic Letter 93-05, "Line Item Technical Specifications Improvements to Reduce Surveillaxe Requ.'rements," then please discuss if the recommendations of NUREG-1366 are compatible with plant operating experience similar to thejustification for the steam line monitors given in WE's October 12,1995, submittal.

Response: l As stated in the December 15,1997 submittal, the required surveillance of the control room emergency ventilation system is described in PBNP Technical Specifications section 15.4.11. The radiation monitors (RE-101 and RE-235) are considered part of the control room emergency ventilation system and therefore these monitors are considered to be implicit within the surveillance requirements contained in TS 15.4.11. Addition of a line item in TS Table 15.4.1-1 will provide explicit guidance fcr the check, calibration, and test of the RE-101 and RE-235 channels.

Therefore, in attachment 2 to this letter, the addition of these channels to the line item 36 is proposed. The proposed quarterly channel functional test frequency isjustified with the proposed change to insert these monitors in the radiation monitoring system line item. The requirement to check the monitors each shift and calibrate the monitors on a refueling interval will be maintamed.

Question:

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2. The air ejector monitors 1(2)RE-215 or 1(2)RE-225 can provide indication of steam generator  ;

primary-to-secondary leak or may be indicative ofpotential airbome radiation exposure in the ,

turbine hall Currently, TS 15.3.1.D.8, states in part, " Secondary coolant gross radioactivity l l shall be monitored continuously by an air ejector gas monitor." To ensure that these monitors are operable, it would seem that performance of checks, calibrations, and testing of RE-215 and RE-225 currently required by TS Table 15.4.1-1 should be performed. If the monitors are l

<. s-Attachment to NPL 98-0429 Page 2 of 5

, added, justify any changes you propose regarding the table entries if diffemnt frcm the RMS entries. Specifically, if WE plans to increase the .esting to quarterly in accordance with Generic Letter 93-05, then please discuss if the recommendations of NUREG-1366 are compatible with plant operating experience similar to thejustification for the steam line monitors giv ;;in WE's October 12,1995, submittal.

Response

RE-215 provides continuous monitoring of the gross radioactivity in the condenser air ejector gases for the associated unit. There are two RE-215 monitors, one for each unit RE-225, the combined air ejector monitor, provides continuous monitoring of the gross radioactivity in the condenser air ejector gases of both units after the flow from the air ejectors is combined. There is only a single RE-225 monitor. The requirement to continuously monitor secondary coolant gross radioactivity by an air ejector monitor in accordance with TS 15.3.1.D establishes the operability requirement for this monitoring function. RE-215 or RE-225 can be used to satisfy this monitoring requirement, but nomially RE-215 is the monitor that is used. TS 15.3.1.D requires secondary coolant gross activity to be measu ed daily to cvaluate steam generator leak tightness if the air ejector monitor is not operating. This alternative surveillance would be required to be invoked if both RE-215 and '.

RE-225 are not operating. Current practice requires the alternative surveillance to be invoked if RE-215 is not operating.

The channels associated with these monitors (IRE-215,2RE-215, and RE-225) are connected through data acquisition modules to the radiation monitoring system control terminal. The control terminal continuously scans the associated RMS channels available through eight data acquisition modules. If a channel changes from the " normal" status, this would be readily apparent based on status change of the associated channel on the radiation monitoring system control terminal (RMS-CT), this information is also relayed to the plant process computer system. The channel status indications include the following: NORMAL, FAILURE, UNINITIALIZED, MAINTENANCE / CALIBRATE, STANDBY, ALERT, HIGH ALARM AND FAIL HIGH. A status change for channels RE-215 or RE-2~.5 also rauses a control room alarm on the C-20 auxiliary system instrument panel. Tlie automatic monitoring of the associated channels by the l RMS-CT and the PPCS assist the rapid detection of channel inoperability. The perfonnance of channel checks and channel calibration for the air ejector radiation monitors will provid: additional assurance that the air ejector monitors are functioning properly. Therefore, addition of a line item to perform these surveillance is proposed in Attachment 2 to this letter.

Question:

3. The August 15,1997, request for additional information (RAI) requested WE to verify that the monitors included in the radiation monitoring sysicm as described in the tables appended to the RAI were accurately identified. Included in the lists provided with the RAI were 1(2)RE-126, j 1(2)RE-127, and 1(2)RE-128. Final Safety Analysis Report Section 7.7.4.4," Containment High-Range Radiaion," states, " Independent of the radiation monitoring system described in I

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1 Attachment to NPL 98-0429 Page 3 of 5 l

l . section 11.2.3, three radiation detectors per containment structure sense high radiation levels l which might exist in the post-accident environment." Please clarify that these monitors are not in the RMS and are included in Table 15.4.1-1 as line item 25.

Response

l The containment high range radiation monitors,1(2)RE-126,1(2)RE-127, and 1(2)RE-128, are part of the radiation monitoring system at PBNP. FSAR section 11.2.3 describes the RMS control terminal and associated data acquisition modules. These radiation monitors (RE-126,127, and 128) do not interface with the RMS control terminal or the associated data acquisition modules.

Therefore, the statement in FSAR section 7.7.4.4 that states that these monitors are independent of the radiation monitoring system described in section 11.2.3 is correct. These monitors have meters and alarm functions on the associated unit auxiliary system instrument panels (C-20) and can be monitored using the plant process computer system. The surveillance requirements for these monitors are included in Table 15.4.1-1 as line item 25. The LCO requirements for these monitors are included in TS Table 15.3.5-5, line item 7. An additional change to the surveillance requirements for the associated line item (#25) in TS Table 15.4.1-1 is proposed in Attachment 2 to this letter.

Question:

4. For RE-218, waste disposal system liquid monitor, and RE-223, waste distillate overboard monitor, please justify the change in the frequencies of the check, calibrate, and test columns.

Specifically, if WE plan, to increase the testing to quarterly in accordance with Generic Letter 93-05, then please discuss if the recommendations of NUREG-1366 are compatible with plant operating experience similar to the justification of the main steam line monitors given in WE's October 12,1995, submittal.

Response

Review of the relevant guidance (Generic Letter 93-05, NUREG -1366, and NUREG-1431) shows that post accident monitor instruments such as; the steam line release monitors and the containment high range radiation monitors, are typically subject to a monthly channel check and calibration on a refueling interval. No separate channel functionc! test is required for post-accident monitoring instrumentation because these monitors do not perfoim any trip or actuation function. Therefore, propased changes in Attachment 2 for the main steam line and containment high range monitors are based on this guidance. These changes arejustified based on plant operating experience. In particular,1he automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability.

Attachment 2 provides the proposed surveillance frequencies for RE-218 and RE-223. The I proposed channel functional test requirement for these channels is quarterly. Tb, current Technical Specifications in TS Table 15.4.1-1, line item 36, requires a monthly channel functional test for the radiation monitoring system. The decreased Lequency from monthly to quarterly for the channel functional test isjustified based on plant operating experience. In particulai, the performance of a I

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. Attachment to NPL 98-0429 Page 4 of 5 source check prior to start of a release provides assurance that the channel is responding properly to

.. a source of radiation. The continuous automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability during a release. The quarterly channel functional test is consistent with the channel functional test requirements for other channels that cause trip or initiation actioris, such as, steam generator pressure, containment pressure,

- pressurizer water level, pressurizer pressure, steam generators level, reactor coolant flow, reactor coolant temperature, and nuclear power range. The proposed surveillance for RE-218 and RE-223 will continue to include channel checks each shift when a waste liquid release (discharge) is occurring.

Question:

5. During the review of Table 15.4.1-1, the definition ofpower (PWR) and ALL in the notation section of Table 15.4.1-1 incorrectly refers to 15.1.n for the definition oflow power operation.

the correct reference should be 15.1.m. Please verify that this is an administrative oversight and submit the appropriate changes.

Response

This is correct. A request to change the references to definition 15.1.n to 15.1.m in the descriptions }

for PWR and ALL in the notation section of Table 15.4.1-1 is provided in Attachment 2. These  !

changes correct errors introduced during previous Technical Specifications amendments.

Question:

6. During the review of Table 15.4.1-1, notes 10 and 21 refer to the " Overpressure Mitigating System." This nomenclature was changed in the majority of the TS including Table 15.4.1-1, line item 32, as a result of Amendments 172 and 176. Please submit the appropriate TS changes to correct this inconsistency.

Response

This is correct. A request to change " overpressure mitigating (mitigation) system" to " low temperature overpressure protection system"in notes 10 and 21 of Table 15.4.1-1 is provided in Attachment 2. 7ese chenges correct errors introduced during previous Technical Specifications j- amendments.

Question:

7. Thejustification for removing RE-214 auxiliary building vent exhaust gas monitor is that it is presently not required for mitigation of any accident for Pt. Beach. However, TSCR-204 does credit auxiliary building releases being filtered and since no changes were proposed to add the 1-

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Attachment to NPL 98-0429 Page 5 of 5

, auxiliary building monitors into the limiting conditions for operation and since no surveillance requirements were proposed to ensure the instrumemation remains checked, calibrated, or tested, please provide additionaljustification for removal from the TS or plans to address these requirements for TSCR-204.

Response

As stated previously, the auxiliary building exhaust filtration is not currently required for mitigation of any accident for "GNP. Primary auxiliary building filtration is used in analyses in support of TSCR-204, only for control room dose mitigation. TSCR-204 proposes to modify the primary auxiliary filtration system as necessary to allow manual or automatic operation of the system prior to the initiation of containment sump recircula' ion followir.g a loss of coolant accident. If automatic operation is utilized, it would likely be preferable to use containment isolation initiation signal, rather than radiation. We do not currently anticipate using RE-214 for any protective action initintion function. If our plans change as the final design progresses, appropriate Technical Specifications changes will be requested at that time, j

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.. .. j Attachment to NPL 98-0429 l Page1of3 ATTACIIMENT 2 SUPPLEMENT TO TSCR 172 DESCRIPTION OF CUD. RENT IJ. CENSE CONDITION, PROPOSED CIIANGES AND JUSTIFICATIONS FOR PROPOSED CIIANGES 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, March 26,1996, and December 15,1997, proposes to change Technical Specifications surveillance requirements for the radiation monitoring system from monthly to quarterly and

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specify only the necessary monitors.

The following modifications to TSCR 172 were identified during the preparation of the response to the NRC's request for additional information:

Description of current license condition: Technical Specifications section 15.4.1 is called

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" Operational Safety Review." Technical Specifications section 15.4.1 applies to items directly related to safety limits and limiting conditions for operation. In particular, Technical Specifications surveillance requirements contained in Table 15.4.1-1," Mini'aum Frequencies for Checks, Calibrations, and Tests ofInstrument Channels," line item number 36, requires a daily j check, a refueling interval calibration, and a monthly test of the radiation monitoring system. J TS Table 15.4.1-1, line item number 25, requires a check each shifl, a refueling interval -

calibration, and a monthly test of the containment high range radiation monitors.

1. Proposed Change: Delete the channel test requirements and change the channel check requirement from the current requirement of"cach shifl" to " monthly" for item 25, containment high range radiation monitors.

Justification: The containment high radiation monitors are post accident monitoring instrumentation, with limiting conditions for operation as specified in Point Beach Technical Specifications Table 15.3.5-5. The LCO requirements for these monitors require a report to be generated within 30 days in accordance with TS 15.6.9.2.D if the minimum number of two operable channels is not restored within 7 days. Periodic channel functional testing is not necessary because these channels are used only for monitoring and no required trip or initiating action is associated with these monitors. The refueling frequency calibration and the monthly channel check properly verify channel operability. The containment high range radiation monitors con;ain sources that provide e contiauous reading that is used to verify the operability of the monitors. Most radiation monitor failures are discovered based on alarms being generated or during a channel check. Therefore, the proposed monthly channel checks provides adequate assurance that the monitors are operable. These proposed calibration and  ;

channel check frequencies are consistent with the guidance contained in NUREG-1431,

" Standard Technical Specifications, Westinghouse Plants," Revision 1. i i

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Attachment to NPL 98-0429 Page 2 of 3

2. ' Propo's ed Change: Add RE-101 Control Room Monitor and RE-235 Control Room Noble Gas Monitor to item 36 in TS Table 15.4.1-1. These monitors will use the "Each Shift" designation of"S" 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.

Justification: These monitors are needed for mitigation of dose in the control room. Either monitor is able to automatically initiate the required control room ventilation emergency mode. The " plant conditions when required" column for this surveillance will continue to specify "All." The change from monthly channel functional testing to allow the channel functional testing to be performed quarterly is based on plant operating ex; erience. In particular, the automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability. The channel check each shift also assists with the detection of channel malfunction. Most radiation monitor failures are discovered based on alarms being generated or during a channel check. These proposed test, calibration and channel check frequencies are consistent with the guidance contained in NUREG-1431," Standard Technical Specifications, Westinghouse Plants," Revision 1.

3. Proposed Change: Add RE-215 Air Ejector Monitor to item 36 in TS Table 15.4.1-1. This monitor will use the " Daily" designation of"D" as modified by note 1 for the " Check" requirement, and "R" as modified by note 14, is the refueling frequency for the

" Calibration" requirement.

Justification: RE-215 is necessary for moni;oring primary to secondary leakage in accordance with TS 15.3.1.D," Leakage of Reactor Coolant." The " plant conditions when required" column will continue to be "All." Channel testing in excess of the refueling calibration is not necessary because the daily channel check and automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability. There is no required trip or initiating action associated with this monitor.

Additionally, most radiation monitor failures are discovered based on alarms being generated or during a channel check. This monitor is not Jescribed in NUREG-1431, " Standard I Technical Specifications, Westinghouse Plants," Revision 1.

4. Proposed Change: Delete the channel test requirements and change the channel check requirement from the current requirement of" daily" to " monthly" for RE-231 and RE-232,  !

the steam line radiation monitors in line item 36.

1 Justification: The steam line monitors (RE-231 and RE-232) are post accident monitonng i instrumentation, with limiting conditions for operation (LCO) as specified in Point Beach TechnicM Specifications Table 15.3.5-5. The LCO requirei.nents for these monitors require a l report to be generated within 30 days in accordance with TS 15.6.9.2.E if the minimum number of two operable channels is not restored within 7 days. Periodic channel functional  ;

testing is not necessary because these channels are used only for monitoring and no required l

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Attachment to NPL 98-0429 Page 3 of 3

• trip or initiating action is associated with these monitors. The refueling frequency calibration and the monthly channel check properly verify channel operability. The automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability. Most radiation monitor failures are discovered based on alarms being generated or during a channel check. Therefore, the proposed monthly channel I checks provides adequate assurance that the monitors are operable. These proposed calibration and channel check frequencies tent with the guidance contained in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," Revision 1.

5. Proposed Change: Change the references to definition 15.1.n to 15.1.m in the descriptions )

for PWR and ALL in the notation section of Table 15.4.1-1.

Justification: These changes correct errors introduced during prev ous Technical  !

' Specifications amendments. These changes are administrative because the intended {

requirements have not been changed.

6. Proposed Change: Change " overpressure mitigating (mitigation) system" to " low

. temperature overpressure protection system in notes 10 and 21 of Table 15.4.1-1.

Justification: These changes correct errors introduced during previous Technical Specifications amendments. These changes are administrative because the intended requirements have not been changed.

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Attachment to NPL 98-0429 Page1of4 ATTACIIMENT 3 TECIINICAL SPECIFICATIONS CIIANGE REQULST 172 SAFETY EVALUATION INTRODUCTION Wise:nsin Electric Power Company (Licensee)is applying for amendments to facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant (PBNP), Units 1 and 2. The proposed changes revise Technical Specifications (TS) Section 15.4.1, " Operational Safety Review," Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests of Instrument Channels." The proposed changes reduce the burden associated with radiation monitoring system surveillance requirements consistent with guidance contained in GL 93-05, "Line-item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing during Power Operation," and NUREG-1366," Improvements to Technical Specifications Surveillance Requirements," as currently embodied in NUREG-1431, " Standard Technical Specifications - Westinghouse Plants."

The requirement to perform a r.1onthly test of the radiation monitoring system is particularly onerous and distracting to the reactor operators. This testing generates about 350 alarms in the control room each month, with minimal discemible safety benefit. Only the post-accident monitors and the condenser air ejector monitors have associated limiting conditions for operation. The radiological effluent monitors are specified separately. The proposed changes will reduce this by performing testing on a quarterly basis on only the channels that initiate required actions. This should reduce the number of alarms to about 30 per quarter.

EVALUATION As the name " radiation monitoring system" implies, the predominant function of this system is monitoring. There are four channels that initiate required actions (RE-101 and 235 for control room emergency filtration and RE-218 and 223 for liquid discharge isolation), there are ten channels that are required for post-accident monitoring (l&2RE-231 and 232 for steam line radiation monitoring and 1&2RE-126,127, and 128 for containment high range radiation monitoring;, and there are two channels that are used for detecting steam generator tube leakage (1&2RE-215). Appropriate requirements have been pronosed for each of these monitors as follows:

Control Room Emergency Filtration RE-101 and RE-235 initiate control room emergency filtration. This fimetion is necessary for mitigation ofoperator dose in the control room. The proposed surveillance requirements for I

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Attachment to NPL 98-0429 Page 2 of 4 these monitors include a channel check each shift, a refueling interval calibration, and a quarterly channel functional test.

The proposed channel check each shift is a more restrictive requirement for this surveillance.

The current Technical Specifications requirement for the channel check of the entire raciation monitoring system is daily. The proposed channel check frequency along with the continuous monitoring provided by the radiation monitoring system control terminal and plant process computer system will allow rapid identification ofinstrument malfunctions. The proposed channel check surveillance frequency is consistent with NUREG-1431, " Standard Technical Specifications - Westinghouse Plants." i

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The proposed refueling interval calibration is consistent with the current Technical Specifications requirements for these moritors. This surveillance frequency is also consistent with NUREG-1431, " Standard Technical Specifications - Westinghouse Plants." l The proposed quarterly channel functional test is a less restrictive requirement for this surveillance. The current Technical Specifications requirement for the channel functional test is monthly. This surveillance is used to detect malfunctions in the associated initiation circuitry for comrol room emergency filtration actuation. The proposed quarterly surveillance interval is consistent with other channels that perform actuation functions, so .h as pressurizer pressure.

~ This change is furtherjustified based on plant operating experience. In particular, the automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel inoperability. The channel check each shift also assists with the detection of channel

. malfunction. Most radiation monitor failures are discovered based on alarms being generated or .

during a channel check. The proposed test frequency is consistent with the guidance contained in  !

NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," Revision 1. l Ligeld Discharge Isolation The surveillance for RE-218 and RE-223 remains as previously proposed and justified.

RE-218 Waste Disposal System Liquid Monitor - Shuts Waste Liquid Overboard Valve I 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." RE-223

. Waste Distillate Tank Overboard Monitor- Shuts Waste Distillate Overboard Valve 3 FCV-LW-15. In Table 15.4.1-1 under item 36, include RE-218 and RE-223. These control  ;

function are provided to prevent accidental release of waste liquid as described in FSAR Section

~ 14.2.2 " Accidental Release-Recycle or Waste Liquid."

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- 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 ,

j surveillance effectively prevents use of the dischange flowpath. A shiftly channel check will

} continue for the duration of the release. The setpoints for these channels will be controlled by

[ the Radiological Eff'uent Control Program (RECP), which is a licensee controlled program as i

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Attachment to NPL 98-0429 Page 3 of 4 de' scribed'in Technical Specifications Change Request 174. A refueling calibration will be maintained and quarterly channel functional testing will be performed. These surveillance requirements are applicable during all plant conditions.

The proposed quarterly channel functional test requirement for this surveillance is consistent with the current RETS and proposed to be maintained in the RECP. This change is further justified based on plant operating experience. In particular, the automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel .

inoperability. The source check prior to discharge and the channel check each shift when the discharge is in progress also assists with the detection of channel malfunction. Most radiation monitor failures are discovered based on alarms being generated or during a channel check.

Post-accident Radiation Monitors As previously stated, there are ten channels that are required for post-accident monitoring; 1&2RE-231 and 232 for steam line radiation monitoring and 1&2RE-126,127, and 128 for containment high range radiation monitoring.

The containment high radiation monitors are post accident monitoring instrumentation, with

. limiting conditions for operation as specified in Point Beach Technical Specifications Table 15.3.5-5. The LCO requirements for these monitors require a report to be generated within 30 days in accordance with TS 15.6.9.2.D if the minimum number of two operable channels is not restored within 7 days. Periodic channel functional testing is not necessary because these 4 channels are used only for monitoring and no required trip or initiating action is associated with these monitors. The refueling frequency calibration and the monthly channel check properly verify channel operability. The containment high range radiation monitors contain sources that provide a continuous reading that is used to verify the operability of the monitors. Most

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radiation monitor failures are discovered based on alarms being generated or during a chanrel check. Therefore, the proposed monthly channel checks provides adequate assurance that the monitors are operable. These proposed calibration and channel check frequencies are consistent with the guidance contained in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," Revision 1.

The steam line monitors (RE-231 and RE-232) are post accident monitoring instrumentation, with limiting conditions for operation (LCO) as specified in Point Beach Technical Specifications Table 15.3.5-5. The LCO requirements for these monitors require a report to be generated within 30 days in accordance with TS 15.6.9.2.E if the minimum number of two operable channels is not restored within 7 days. Periodic channel functional testing is not necessary because these chrmis are used only for monitoring and no required trip or initiating l

action is associated with thuc monitors. The refueling frequency calibration and the monthly l channel check properly verify channel operability. The automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detection of channel ireperability. Most radiation monitor failures are discovere:! based on alarms being generated or during a channel l

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, Attachment to NPL 98-0429 Page 4 of 4 check. Therefore, the proposed monthly channel checks provides adequate assurance that the monitors are operable. These proposed calibration and channel check frequencies are consistent with the guidance contained in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," Revision 1.

Condenser Air Ejector Monitors RE-215 is necessary for monitoring primary to secondary leakage in accordance with TS 15.3.1.D, " Leakage of Reactor Coolant." The " plant conditions when required" column will continue to be "All." Channel testing in excess of the refueling calibration is not necessary because the daily channel check and automatic monitoring of the associated channels by the RMS-CT and the PPCS assist the rapid detechon of channel inoperability. There is no required trip or initiating action associated with this monitor. Additionally, most radiation monitor failures are discovered based on alarms being generated or during a channel check. Technical Specifications Section 15.3.1.D requires secondary gross activity to be measured daily if the air

. ejector monitor is not operating. The proposed daily channel check is consistent with the current Technical Specifications requirement for RMS channel checks and the daily requirement for sampling if the monitor is not operating. This monitor is not described in NUREG-1431,

" Standard Technical Specifications, Westinghouse Plants," Revision 1.

CONCLUSION The proposed Technical Specifications for the radiation monitoring system will provide adequate assurance that the required circuitry and monitors are operable, consistent with the required functions that these monitors perform and based on guidance as appropriate from NUREG-1431,

" Standard Technical Specifications, Westinghouse Plants," Revision 1.

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Attachment to NPL 98-0429 Page 1 of 2 ATTACIIMENT 4 TECIINICAL SPECIFICATIONS CIIANGE REQUEST 172 "NO SIGNIFICANT IIAZARDS CONSIDERATION" The revised edited Technical Specification pages for TSCR 172 are attached. The "No Significant Hazards Consideration," provided with the December 15,1997, submittal of TSCR 172, 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 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 feedwater 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 rupture, steam pipe rupture, control rod ejection, and primary coolant system ruptures.

This license 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 probability of any initiating events for accidents previously evaluated. In particular, these changes affect radiation monitors which do not initiate accidents.

The consequences of the accidents previously evaluated in the PBNP FSAR are determincd 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 l equipment and systems. The changes proposed in this license amendment request provide appropriate surveillance requirements for the radiation monitoring system.

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Attachment to NPL 98-0429 Page 2 of 2 l

'Ihe proposed changes reduce the burden associated with radiation monitoring system required surveillance by establishing surveillance 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 frequency for monitors that perform a trip or initiation

, function from monthly to quarterly. The proposed changes provide appropriate l surveillance for these monitors and thus do not increase the probability 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 under the proposed Technical Specifications change will not create the possibility of a new or different kind of accident from any accident previously evaluaied.

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 or events 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 surveillance requirements for the radiation monitoring system will not cause failures of equipraent 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 Point 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 monito s 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 co'ntainment are not being changed.