ML20215H566

Proposed Tech Specs Re Surveillance Requirements for Radiological Effluent Monitoring Instrumentation

ML20215H566
Person / Time
Site:	Cooper
Issue date:	10/17/1986
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20215H554	List: ML20215H551 ML20215H566
References
NUDOCS 8610240025
Download: ML20215H566 (6)

Text

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Attachmsnt 1 Revised Technical Specifications for Surveillance Requirements of Radiological Effluent Monitoring Instrumentation Revised Pages 216q 216v 216r 216w Section 3.21.A.2 of Cooper Nuclear Station (CNS) Technical Specifications provides.the limiting condition for operation for gaseous effluent monitoring instrumentation. Specification' 3.21. A.2.a and Table 3.21. A.2 require these various instruments to be operable only during monitored system operation (i.e. Steam Jet Air Ejector and Augmented Off-Gas) or r'eleases via the monitored pathway. ;7ecification 4.21.A.2.b says the instrumentation shall be demonstrated operable by performance of the channel check, source check, channel calibration, and channel. functional test operations during the modes and at the frequencies shown in Table 4.21.A.2. However, Table 4.21.A.2 gives the applicable conditions for performing.the channel-check only. This leaves uncertainty about what the applicable conditions are for performing the other three operations. The channel check conditions are the same as the applicability conditions given in Table 3.21. A.2 for the instruments. The District believes these conditions should apply to the source check, channel calibration, and channel functional test as well. This is based on: 1) The instruments are required to be operable during the conditions specified in Table 3.21.A.2 and all four instrument operations are required to demonstrate operability, 2) Specification 1.Y says surveillance requirements shall be applicable during the operational conditions associated with individual LCO's' unless otherwise stated. It does not follow that the lack of conditions given for the three instrument operations implies they are to be performed at all

' times whether the instruments are required to be operable or not.

Uncertainty in the surveillance requirements for gaseous effluent monitors was

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a contributing cause of an inspection violation the District received (Inspection Report 50-298/85-26). Although the applicable Technical Specifications have recently been superseded by RETS, the District believes the new RETS should be clarified to prevent any repeat violation. As part of corrective actions, the District is proposing this change to ensure that explicit guidelines are provided which relate s'urveillance requirements with the various modes of plant operation.

Nebraska Public Power District requests to change CNS Technical Specifications to clarify the applicable conditions for performing the source check, channel calibration, and channel functional test operations for the gaseous effluent monitors. The revision involves the following:

1. Add an Applicability column to Table 4.21.A.2 for the various monitoring instrumentation that applies to all instrument test operations.

2. Add the # note to Table 4.21.A.2 and explained on page 216w.

For reasons similar to the above, the District also requests to change the CNS Technical Specifications to clarify the applicable conditions for performing the source check, channel calibration, and channel functional test operations for the liquid effluent monitors. Specificaion 3.21.A.1.a and Table 3.21.A.1 require these instruments to be operable only during releases via the monitored pathway. Specification 4.21.A.I.a states what performance tests are required to demonstrate operability, however, Table 4.21.A.1 gives the j

8610240025 861017 PDR ADOCK 05000298 PDR

f, applicable ' conditions for performing the channel . check only. The District believes these conditions apply to the source check, channel calibration, and channel functional as well for the same reasons given for the gaseous instruments above. The revision involves the following:

1. . Add an Applicability column to Table 4.21. A.1 for the various liquid monitoring instrumentation . that applies to all instrument test operations.

2. Add the # note to Table 4.21.A.1 and explained on page 216r.

Evaluation of this Revision with Respect to 10CFRSO.92 The enclosed _ Technical Specification change is judged to involve no significant hazards based on the following:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation The proposed amendment clarifies the surveillance requirements of the radiological effluent monitoring instruments. It does not change these instruments' operability requirements or their limiting condition for operation. Performance of the various surveillance tests are still required to demonstrate instrument operability. During operation when releases are being made, the monitoring instrumentation is in operation-i and subject to the various surveillance tests to verify operability.

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Monitoring capability will be present as assumed in previous evaluations of accidents to enable accurate determination of any risk to member of the public offsite. Any gaseous radiological release will continue to be monitored as before. Because of this, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?

Evaluation The proposed amendment will not allow any new plant mode of operation so it does not create the possibility of a new or different kind of accident.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Evaluation The proposed amendment clarifies the surveillance requirements and does not change the operability or limiting conditions of operation for the radiological monitoring instrumentation. These instruments are still required to have their operability demonstrated by the performance of their surveillance requirements. Monitoring capability during releases will not be reduced from that assumed in previous evaluations. The proposed license amend =ent does not involve a significant reduction in a margin of safety.

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TABLE 4.21.A.1 -

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS- .,

i i

, CHANNEL

! CilANNEL SOURCE CllANNEl. FUNCTIONAL- 'APPLIC-INSTRUMENT CllECK CllECK CALIBRATION TEST ABILITYi *

1. Gross Beta or Gamma Radioactivity Monitors Providing Alarm and Automatic Isolation R(3) *

a. Liquid Radwaste Effluents Line D P Q(1)

2. Gross Beta or Gamma Radioactivity Monitors Providing Alarm but not Providing Auto-j matic Isolation l a. Service Water System Effluent Line D M R(3) Q(2)

\ u%

i E j i

! 3. Flow Rata Heasurement Devices

a. Liquid Radwaste Effluent Line D(4) NA R SA

• I 4

l i

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E NOTES FOR TABLE 4.21.A.1

• During releases via this pathway.

J Channel (s) shall be.0PERABLE and in-service as indicated except that outages for maintenance and required tests, checks, or calibrations are permitted.

'(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway occurs.for Conditions 1 and 2 below and control room alarm annunciation occurs for Conditions 1, 2, and 3 below.

1. Instrument-indicates measured' levels ab'ove the alarm / trip setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm / trip setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure.

4. Instrument controls not set in operate mode.

(3) The CHANNEL CALIBRATION shall be performed according to established station calibration procedures.

(4) CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.

FREQUENCY NOTATION:

S = At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

D = At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

W = At least once per 7 days.

M = At least once per 31 days.

= At least once per 92 days.

Q SA = At least once per 184 days.

A = At least once per year.

R = At least once per 18 months.

-S/U = Prior to each reactor startup.

P = Completed prior to each release.

NA = Not applicable.

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TABLE 4.21.A.2

• RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS ,

CHANNEL CHANNEL SOURCE CliANNEL FUNCTIONAL APPLIC-INSTRUMENT CHECK CIIECK CALIBRATION TEST ABILITY #

1. Steam Jet Air Ejector

a. Noble Gas Activity Monitor D M R(3) Q(2) R(1) ***

a

b. Effluent System Flow Rate Measuring Dev' ice D NA R Q *

2. Augmented Offgas Treatment System Explosive Gas Monitoring System

a. Ilydrogen Monitor (2% Monitor) D NA Q(4) M **

3. Reactor Building Ventilation Monitoring System

/, a. Noble Gas Activity Monitor (KAMAN) D M R(3) Q(S)

• E j b. Iodine Sampler Cartridge W NA NA NA *

c. Particulate Sampler Filter W NA NA NA

• d.

Effluent System Flow Rate Measuring Device D NA R Q. *

e. Sampler Flow Rate Measuring Device D NA .R Q- *

1. Isolation Monitor (CE)

D Q R(3) R(1) *

4. (****)

a. Noble Gas Activity Monitor (KAMAN) D M R(3)

• Q(S)

b. Iodine Sampler W NA NA 'NA *

c. Particulate Sampler W NA NA NA *

d. Effluent System Flow Rate Measuring Device D NA R Q. *

e. Sampler Flow ' Rate Monitor D NA R Q

• e-

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NOTES'FOR TABLE 4.21.A.2

• During releases via this pathway.

• • During augmented offgas treatment system operation.

• • • During operation of the Steam Jet Air Ejector.

• • • • Elevated Release Point (ERP) Monitoring System, Radwaste Ventilation Monitoring System, and Turbine Building Ventilation Monitoring System

1. Channels shall be operable and in service as indicated except that outages are

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permitted for the purpose of required tests, checks, calibration, or for maintenance.

(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm / trip setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure.

4. Instrument controls not set in operate mode.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that' control room alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm / trip setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure.

4. Instrument. controls not set in operate mode.

(3) The CHANNEL CALIBRATION shall be established in accordance with established station calibration procedures.

(4) The CHANNEL CALIBRATION shall include the use of a standard gas sample containing a percentage of hydrogen to verify accuracy of the monitoring channel in its operating range.

(5) Same as (2) except Parts 3 and 4 are deleted.

FREQUENCY NOTATION:

S = At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

D = At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

W = At least once per 7 days.

M = At least once per 31 days.

Q = At least once per 92 days.

SA = At least once per 184 days.

A = At least once per year.

R = At least once per 18 months.

S/U =

Prior to each reactor startup.

P = Completed prior to each release.

NA = Not applicable.

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