ML20212D990

Proposed Tech Specs Deleting Item 1.a & Action Statement 26 of Tech Spec Table 3.3-6 Re Trip Functions of Containment Atmosphere Radiation Monitors Associated W/Containment Purge & Control Room Ventilation Isolations

ML20212D990
Person / Time
Site:	Callaway
Issue date:	12/30/1986
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20212D982	List: ML20212D975 ML20212D990
References
NUDOCS 8701050209
Download: ML20212D990 (10)

Text

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T ) TABLE 3.3-6 C RADIATION HONITORING INSTRUMENTATION FOR PLANT OPERATIONS r-h HINIMUM 4 CllANNELS CHANNELS APPLICABLE ALARH/ TRIP FUNCTIONAL UNIT TO TRIP / ALARM OPERABLE H0 DES SETPOINT ACTION E 1. Containment M UAEEh 55!c5cEIE55[ 1 2 ^' f!? 26 c m.,,, :.. _ -. a. m,.a m.. m - -titgh 'GT." 31 '. 32) -

41. -A-Gaseous Radioactivity-RCS Leakage Detection N.A.

I 1,2,3,4 N.A. 29 (GT-RE-31 & 32) f, s - Particulate N.A. 1 1,2,3,4 N.A. 29 Radioactivity-RCS Leakage Detection R (GT-RE-31 & 32) + Y 2. Fuel Building e a. Fuel Building Exhaust-Gaseous Radioactivity-1 2- ^^ 30 tilgh (GG-RE-27 & 28) b. Criticality-liigh Radiation Level

1) Spent Fuel. Pool 1

1 1 15 mR/h 28 (50-RE-37 or 38) 1 15 mR/h 28

2) New Fuel Pool 1

1 (SD-RE-35 or 36) g tri 3. Control Room q C'o Air Intake-Gaseous O ~ Hadioactivity-liigh 1 2 All 27 N (GK-RE-04 & 05) s,

r I. REVIS[oy ~ TABLE 3.3-6 (Continued) N TABLE NOTATIONS "With fuel in the respective fuel storage pool. ""With irradiated fuel in the fuel storage areas or fuel building.

1. Trip Setpoint concentration value (pCi/cm ) is to be established such that 3

the actual submersion dose rate would not exceed 2 mR/h in the control room.

1. 1. Trip Setpoint concentration value (pCi/cm ) is to be established such that 3

the actual submersion dose rate would not exceed 4 mR/h in the fuel building. ?"" '; :t;;i,t : ne:ntr:ti:n ;;iu: (w^i/cm') i: t: b; ::t bli:hed :uch that th: ::tu:1 :ubmer:ic-de:: P:t:.::uld net ex:::d ? '/' '- th: ::r* '- : - buildi g. The :t;;i.t valu: ::y 5: 'ncrc : d up t: th: ::2t!:'e-t ' c f 5;c:i'icati:n 2.11. 2.1 ' ::::rdant: with th: =cthedei:2/ :nd ;2 : :te - 'n thc ::" during ::nt f r nt purg: Or ;;nt pr:;id d.tN: 5 t;;#nt '!2'ue dre net en : d tuice th

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b EL.E TEb - ACTION 27 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 1 hour isolate the Control l Room Emergency Ventilation System and initiate operation of the Control Room Emergency Ventilation System in the recirculation mode. ACTION 28 - With less than the Minimum' Channels OPERABLE requirement, operation may continue for up to 30 days provided an appropriate portable continuous monitor with the 'same Alarm Setpoint is provided in the fuel area. Restore the inoperable monitors to OPERABL2 status within 30 days or suspend all operations involving fuel movement in the fuel building. ACTION 29 - Must satisfy the ACTION requirement for Specification 3.4.5.1. ACTION 30 - With the number of OPERABLE channels one less than the Minimum Channels OPERASLE requirement, within 1 hour isolate the Fuel Building Ventilation System and initiate operation of tne Emergency Exhaust System to maintain the fuel building at a negative pressure. e ) .s CALLAWAY - UNIT 1 3/4 3-40

TABLE 3.3-13 N RADIDACTIVE GASE005 EFFtuENT HONITORING INSTRUMENTATION ~ n C HIN! HUN CilANNELS $5 OPERABLE APPLICABILITY ACTION INSTRtMENT E 1. WASTE GAS 160 LOUP SYSTEM Explosive Gas Q Honitoring System ^^ 44 e 1/recombiner flydroGen Monitors a. 42 2/recombiner b. Oxygen Monitor 2. Unit Vent System a 40 1 Hoble Gas Activity Honitor-a. Providing Alarm (GT-RE-21) 43 1 b. Iodine Sampler 'j ^ 43 1 Y c. Particulate Sampler 4's 1. d. Flow Rate 39 1 Sampler flow Rate Honitor e. 3. Containment Purge System Noble Gas Activity Honitor - Providing a. Alarm and Automatic Termination of Release 41 2 (GT-RE-22, GT-RE-33) 43 1 b. Iodine Sampler 43 m 1 c. Particulate Sampler D1 45 H.A. d. Flow Rate 4' 39 3 1 Sampler Flow Rate Monitor e. M

CN 2 TABLE 3.3-13 (Continuedl TABLE NOTATIONS k. At alI times.

• • Ouring WASTE GAS HOLD UP SYSTEM operation.

ACTION STATEMENTS ACTION 38 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank (s) may be released to the environment for up to 14 days provided that prior to initiating the release: At least two independent samples of the tank's contents are a. analy:ed, and At least two technically qualified members of the facility b. staff independently verify the release rate calculations and discharge valve lineup. Otherwise, suspend release of radioactive effluents via this pathway. ACTION 39 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated based on fan status and operating curves or actual measurements at least once per 4 hours. ACTION 40 - With the number of enannels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once per 12 hours and these samples are analy:ed for radioactivity within 24 hours. ~;"4~d ' ' " ' *"= ACTION 41 "'.*,h th: i-h:. :' :r--f r ".oE"* ELE Mr s

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o. acceso,e -., -. < - - - - - + <-wo. -.a enor mr , -j,y?iy ] A.h-{~ J {E:-]l.m3., ' h ydf-[ [ ~ ' ACTION 42 - With the Outlet Oxygen Mcnitor channel inoperable, operation of the system may continue provided grab samples are taken and analyzed at least once per 24 hours. With both oxygen channels or both the inlet oxygen and inlet hydrogen monitors inoperable, suspend oxygen supply to the recombiner. Addition of waste gas to the system may continue provided grab samples are taken and analyzed at least once per 4 hours during degassing operations and at least once per 24 hours during o ner operations. ACTION 43 - With the number of cnannels OPERABLE less than required by the Minimum Channels NERASLE requirement, effluent releases via the affected qathway may continue for up to 30 days provided samples are coat.nuously collected with auxiliary sampling equipment as required in Table 4.11-2. ACTION 44 - With the number of channels GPERA8LE one less enan required by the Minimum Channels OPERABLE requirement, suspend oxygen supply to the recombiner. ACTION 45 - Flow rate for this system shall be based on fan status and operating curves or actual measurements. CALLAWAY - UNIT 1 3/4 3-71

ULNRC-14 23 Attachmsnt 1 + INSERT A ACTION 41 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, PURGING of radioactive effluents via this pathway may continue for 24 hours. With both channels inoperable, immediately suspend PURGING of radioactive effluents via this pathway.

ULNRC-14 23 SAFETY EVALUATION This amendment application requests that Item 1.a and Action Statement 26 of Technical Specification Table 3.3-6 be deleted. This would involve the removal of the isolation (trip) functions of the containment atmosphere radiation monitors associated with containment purge isolation and control room ventilation isolation. The indication and alarm functions of these monitors would be retained for RCS leakage detection. To meet single failure criteria, Item 3.a of Technical Specification Table 3.3-13 would be revised to require both containment purge radiation monitors to be OPERABLE at all times. This addresses IEEE 279-1971 since ei ther containment purge radiation monitor can initiate containment purge isolation and control room ventilation isolation, as shown in FSAR Figure 7.3-1 (sheet 2). To allow for operational flexibility in performing

test, maintenance, or repair activities, consistent with other Technical Specifications (e.g.,

allowance for one train of ECCS to be out of service for 72 hours), an allowance would be added regarding containment purge radiation monitor operability that would permit one channel to be inoperable, while PURGING, for up to 24 hours. The containment purge isolation function is provided from two independent systems the containment purge radiation monitoring system and the containment atmosphere radiation monitoring system. Containment purge radiation monitors GT-RE-22 and GT-RE-33 are the primary detection devices for containment purge isolation, as stated in FSAR Section 11.5.2.3.2.3. Containment atmosphere radiation monitors GT-RE-31 and GT-RE-32 provide redundant isolation functions while their principal purpose is reactor coolant system (RCS) leakage detection, as stated in FSAR Section 11.5.2.3.2.2. Both systems are designed to give a containment purge isolation signal (CPIS) if radioactivity limits are exceeded. The purge isolation function is also initiated by Phase A containment isolation and manual isolation circuits. The containment purge e xhaust system is provided with redundant particulate and gaseous radiation monitors (GT-RE-22 and 33) in a seismic Category I section of ductwork directly downstream of the outboard purge isolation valves. The e xhaust is then processed through a charcoal adsorber train. Monitoring downstream of the charcoal adsorber is provided by the radiation monitor located in the plant vent (GT-RE-21B). The containment purge radiation monitors provide analog signals to bistable units in the ESF actuation system. The bistables generate redundant trip signals and transmit them to the automatic actuation logic. The requested Technical Specification changes are consistent with design and regulatory requirement for centninment purge isolation, as summarized hereinafter:

r ULNRC-14 23 Attachm:nt 2 1. Single Failure Criteria (IEEE 279-1971) This is satisfied by requiring both containment purge radiation monitors to be OPERABLE in all modes. As shown in FSAR Figure 7.3-1, sheet 2, either monitor can initiate isolation (i.e., ei ther GT-RE-22 or GT-RE-33 can initiate both separation groups 1 and 4 of containment purge isolation). The results of the failure modes and effects analysis for containment purge isolation (FSAR Table 7.3-4) remain the same except that, given the identified failure modes, a minimum of one channel remains available to perform the isolation function. 2. Diversity (Standard Review Plan 6.2.4, BTP 6-4, NUREG-Diverse 0737 Item II.E.4.2.(1), and RG 1.141) parameters are sensed which provide containment purge isolation. These include Phase A containment isolation parameters (initiated by either HI-l containment pressure, low steam line pressure, or low pressurizer pressure) and containment purge radioactivity. Diversity is not lessened by the proposed changes since the principles of operation and the design of the containment atmosphere and containment purge radiation monitors are identical. 3. Electrical Independence (RG 1.6) - Supporting systems for containment purge isolation are the four Class lE 125-V dc power supplies discussed in FSAR Section 8.3.2 and the instrument air system described in Section 9.3.1. Containment purge isolation is fail-safe with respect to these support systems, i.e., after loss of the support

systems, the purge isolation valves are designed to fail closed by spring action.

Interconnection of differing separation groups within the actuation circuitry is by means of digital signal isolation modules. 4. Physical Independence (RG 1.75) - Adequate physical separation or barriers are provided between differing separation

groups, and wiring is routed in separated wireways where appropriate.

The wiring is color-coded with regard to separation group. 5. Automatic Isolation on High Radiation (NUREG-0737 Item II.E.4.2. (7), BTP 6-4, SRP 6.2.4) The references state that the purge lines should be equipped with radiation monitors that are capable of automatically isolating these lines upon detection of high radioactivity. This is satisfied by the containment purge radiation monitors. 6. RCS Leakage Detection (RG 1.45) - Airborne particulate radioactivity should be monitored and airborne gaseous radioactivity may be monitored for RCS leakage detection per RG 1.45 and Technical Specification

ULNRC-1423 Attachm nt 2 3.4.6.1. This requirement is una f f ected by the prop sed changes,-as containment atmosphere radiation monitors will retain their indication and alarm functions. 7. Primary Containment Isolation (GDC

56) - Compliance with this GDC is maintained (i.e.,

one automatic-isolation valve inside containment and one automatic isolation valve outside containment). 8. Control of Radioactive Releases (GDC 60) - Compliance with this GDC is maintained. The plant design retains the means to control the release of radioactive materials in gaseous effluents. 9. Monitoring Radioactive Releases-(GDC 64) - Compliance with this GDC is maintained. The plant design retains the means to monitor the containment atmosphere and effluent discharge paths for radioactivity. 10. Fuel Handling Accident Analysis (FSAR Section 15.7.4 and ULNRC-1237 dated 1-9-86) - This analysis assumes that containment purge is_ isolated within 25 seconds from the time the radioactivity reaches the purge duct. The containment purge radiation monitors satisfy this assumption'. Containment isolation is achieved via the Phase A and Phase B isolation signals for all other accidents analyzed in FSAR Chapter 15 for which containment isolation is required. Pursuant to the above information, this amendment request would not adversely af fect or endanger the health of the general public and does not involve an unreviewed safety question.

ULNRC-14 23 GIGNIFICANT HAZARDS CONSIDERATIONS This amendment request would delete Item 1.a and Action Statement 26 of Technical Specification Table 3.3-6, revise the Minimum Channels Operable requirement for Item 3.a of Technical Specification Table 3.3-13 from 1 to 2, and allow one purge radiation monitor to be inoperable for 24 hours, while PURGING, to perform

test, maintenance, or repair activities.

The following discussions address significant hazards evaluations associated with these changes. Since these changes are inextricably

linked, and in effect constitute a joint change, hazards will be evaluated collectively.

This change does not involve a significant increase in the probability or consequences of an accident previously evaluated. This is based on the fact that the containment purge isolation function is assured by the operability requirements imposed on the containment purge radiation monitors (GT-RE-22 and 33 ), and the RCS leakage detection function is assured by the operability requirements imposed on the containment atmosphere radiation monitors (GT-RE-31 and 32). The revised channel out-of-service allowance for the containment purge radiation monitors is consistent with other Technical Specifications' allowed intervals of inoperability for test and maintenance. This change does not create the possibility of a new or different kind of accident from any accident previously evaluated. This is based on the fact that the method and manner of plant operation is unchanged and the revised operability requirements are consistent with design and regulatory requirements, provide for consistency with other Technical Specifications, and allow maintenance and testing to be performed without entering an Action Statement. This change does not involve a significant reduction in a margin of safety. This is based on the fact that the removal of the containment atmosphere radiation monitors from the trip circuits is compensated by the proposed requirement for both containment purge radiation monitors to be OPERABLE at all times. As such, the requested amendment does not present a significant hazard.}}