ML20205B811

Proposed Tech Spec Changes for one-time Only Extension of 18-month Surveillance Interval for Automatic Depressurization Sys & Permanent Change to Calibr Frequency of Drywell Air Cooler Condensate Flow

ML20205B811
Person / Time
Site:	River Bend
Issue date:	03/18/1987
From:	GULF STATES UTILITIES CO.
To:
Shared Package
ML20205B768	List: ML20205B811 RBG-25505, Application for Amend to License NPF-47 for one-time Only Extension of 18-month Surveillance Interval for Automatic Depressurization Sys & Permanent Change to Drywell Air Cooler Condensate Flow Calibr Frequency.Fee Paid
References
TAC-65128, NUDOCS 8703300047
Download: ML20205B811 (10)

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INSTRUMENTATION 3/4.3.3

! EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTA LIMITING CONDITION FOR OPERATION 3.3.3 The emergency core cooling system (ECCS) actuation instrumentation channels shown in Table 3.3.3-1 shall be OPERA 8LE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3.3-2 and trith EMERGENCY CORE COOLING SYSTEM RESPONS APPLICA81LITY: As shown in Table 3.3.3-1l .

ACTION:

a.

With an ECCS actuation instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column of .

Table 3.3.3-2, declare the channel inoperable until the channel is restored to OPERABLE status with its trip setpoint adjusted consistent '

with the Trip.Setpoint value.

b.

With one or more ECCS actuation instrumentation channels inoperable, take the ACTION required by Table 3.3.3-1.

c. With either ADS trip system "A" or "B" inoperable, restore the inoperable trip system to OPERA 8LE status:

1.

4 Within 7 days, provided that the HPCS and RCIC systems are OPERA 8LE, or 2.

Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, provided either the HPCS or the RCIC system is inoperable.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reducethe within reactor steam24dome following hours, pressure to less than or equal to 100 psig i

SURVEILLANCE REQUIREMENTS

! 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and m CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the y frequencies shown in Table 4.3.3.1-1. '

-om ,

gg 4.3.3.2 LOGIC JiYSTEM FUNCTIONAL TESTS and simulated automatic operation of g all channels shall'-be performed at least once per 18 months.*

bx 4.3.3.3 oc At least once per 18 months, the ECCS RESPONSE TIHE of each ECCS trip 8?t function shown in Table 3.3.3-3 shall be demonstrated to be within the limit.

r1 Each test shall include at least one channel per trip system such that all

$m channels are tested at least once every N times 18 months where N is the total No number of redundant channels in a specific ECCS trip system.

m o.c.

• For ADS, extend to 9/15/S7 for first fuel cycle. Surveillance to be perforned prior to restart following first refuel outage.

RIVER BEND - UNIT 1 3/4 3-30  !

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" TABLE 4.3.3.1-1

;g

• EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRtRENTATION SURVEII. LANCE REQUIREENTS ,

I

) g CHANNEL OPERATIONAL

, g CHANNEL FUNCTIONAL CHANNEL C0lWITIONS FOR tRi!CH j TRIP FUNCTION CHECK TEST CALIBRATION SURVEILLANCE REQUIRED I' c '

H A. DIVISION I TRIP SYSTEM ./ .

! 1. RHR-A (LPCI MDOE) Ale LPCs' SYSTEM ,

M a. Reactor Vessel Water Level - .

Low Low Low Level 1 . S M R 1, 2, 3, 4*, 5*

b. Drywell Pressure - High S M R 1, 2, 3

c. LPCS Pump Discharge Flow-Low S M RI *) 1, 2, 3, 4* , 5*

, d. Reactor Vessel Pressure-Low S M RI ") 1, 2, 3, 4*, 5*

l (LPCS/LPCI Injection Valve -

l Permissive) i e. LPCI Pump A Start Time Delay w Relay NA M

) f. LPCI Pump A Discharge Flow-Low S M Q(,) 1, 2, 3, 4* , 5* ,

g.

R 1,2,3,4*,5*

w LPCS Pump Start Time Delay NA M Q 1, 2, 3, 4*, 5*

a Relay ,

j k

h. Manual Initiation MA R NA 1, 2, 3, 4* , 5*  :

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2. AUTOMATIC DEPRESSURIZATION SYSTEM TRIP SYSTEM "A"#

a. Reactor Vessel Water Level -

• Low Low Low Level 1 S M R 1,2,3

b. Drywell Pressure-High S M R 1,2,3 i c. ADS Timer NA M 1,2,3 Q

i d. Reactor Vessel Water Level - '

RI *}

2 . -

Low Lovel 3 S M 1,2,3 j e. LPCS Pump 01scharge i 1 Pressure-High S M R(,) 1, 2, 3 j f. LPCI Pump A Discharge *

Pressure-High S M R 1,2,3 j g. ADS Drywell Pressure Bypass MA M q 1,2,3 j Timer -

h. ADS Manual Inhibit Switch NA M MA 1,2,3 i

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1. Manual Initiation NA R*** NA 1, 2, 3 i

• • • Extend to 9/15/87 for first fuel cycle surveillance to be perf6rmed prior to restart following l first refuel outage.

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TABLE 4.3.3.1-1 (Continued) y ENERGENCY CORE COOLING SYSTEN ACTUATION INSTRUENTATION SURVEILLANCE REQUIREENTS m

m 5 CHANNEL CHANNEL FUNCTIONAL OPERATIONAL CHANNEL CONDITIONS FOR WHICM i

TRIP FUNCTION CHECK TEST C CALIBRATION SURVEILLANCE REQUIRE 0

}

B. DIVISION II TRIP SYSTEM

1. RHR 8 AND C (LPCI MODE)

a. Reactor Vessel Water Level -

b.

Low Low Low Level 1 S M RI *) 1, 2, 3, 4*, 5*

Drywell Pressure - High S M I 1,2,3

c. Reactor Vessel Pressure-Low S M R '

RI 1, 2, 3, 4*, 5* (LPCI Injection Valve Permissive)

d. LPCI Pump B Start Time Delay w Relay NA M h e. LPCI Pump Discharge Flow-Low S M Q(a) 1, 2, 3, 4* , 5*

w f. R 1, 2, 3, 4*, 5* LPCI Pump C Start Time Delay NA M 1

               "                                                            Relay                                                        Q            1, 2, 3, 4* , 5*

g. Manual Initiation NA R NA 1,2,3,4*,5*

2. AUTONATICDEPhESSURIZATIONSYSTEM  !

TRIP SYSTEM "B"# '

a. Reactor Vessel Water Level - '

1 Low Low Low Level 1 S M R(a) 1, 2, 3 b. c. Drywell Pressure-High ADS Timer S M RI *I 1, 2, 3  : , NA M Q 1,2,3 '

d. Reactor Vessel Water Level - ' '

Low Level 3 S M R(a)

e. 1, 2, 3 LPCI Pump 8 and C Discharge Pressure-High S M R(a) 1, 2, 3

f. ADS Drywell Pressure Bypass Timer NA M

g. ADS Manual Inhibit Switch ' Q 1,2,3 NA M hA 1,2,3

h. Manual Initiation NA R*** NA 1,2,3

                                              *** Extend to 9/15/87 for first fuel cycle surveillance to be performed prior to restart following first refuel outage.

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EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) e. Atleastonceper28monthsfortheADSby:% 1. Performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence, but excluding actual valve actuation. *M 2. Manually opening each ADS valve when the reacter steam dome pressure that: is greater than or equal to 100 psiga and observing a) The control valve or bypass valve position responds accordingly, or b) There is a corresponding change in the measured steam flow, or c) The acoustic monitoring system indicates the valve is open. t i

                             ** Extend to 9/15/87 for first fuel cycle surv,eillance to be performed prior to restart following first refuel outage.
                         "The provisions of Specification 4.0.4 are not appitcable provided the surveillance is performed within 12 hours after reactor steam pressure is adequate to perform the test.

RIVER BENO - UNIT 1 3/4 5-5

ATTACH'7NT 2 GULF STATES UTd11;ES COMPANY RIVER BEND STATION DOCKET 50-458/ LICENSE F). NPF-47 LEAKAGE DETECTION LICENSING DOCUMENT INVOLVED: TECHNICAL SPECIFICATIONS PORTION: 4.4.3.1.C Page 3/4 4-10 REASON FOR REQUEST: A permanent change is being requested in accordance with 10CFR50.92 and 10CFR50.12 (a) (2) (V). GSU has and will make a good faith effort to conduct this surveillance on the current frequency if an outage of sufficient duration occurs. In order to test this component, the plant must be in a shutdown condition. To require the plant to shutdown solely to perform surveillances would cause an unnecessary thermal transient on the plant. GSU requests to amend the subject Technical Specifications contained in Appendix A to the River Bend Station (RBS) Operating License (see Justification) to perform the subject test during a scheduled refueling outage. Should these proposed changes not be granted in a timely manner, GSU will be forced to implement an unnecessary outage during the first cycle. DESCRIPTION Technical Specifications 4.4.3.1.C specifies that the drywell air cooler condensate flow rate monitoring system channel calibration be performed at least once per 18 months. The calibration requirements include entry into the drywell which will require the need for a unit outage. As a result of the first cycle operation the 18 months, including the tolerance of allowed extension in Technical Specification paragraph 4.0.2, will be exceeded on 9/6/87, prior to the next scheduled refueling outage. Extension of the surveillance test period to 24 months will not affect operability or reliability of the system and provides for continued operation, this change maintains full compliance with all acceptance criteria and design bases. Flow monitoring of drywell condensate cooler drains is one of multiple methods provided to detect unidentified leakage. Use of these methods provide compliance with Reg. Guide 1.45 as stated in the RBS FSAR and SER Section 5.2.5.1. Condensate from the coils of the drywell air coolers is piped to the leakage drywell floor drain sump which is considered part of the total unidentified leakage. The flow rate is monitored by a flow transmitter in the condensate drain line and an analog signal is sent to an alarm unit by the flow indicating switch when the nominal trip setpoint is reached. The condensate is measured twice, once as condensate flow rate and then as a portion of the drywell leakage floor drain sump flow rate. It is for the drywell leakage floor drain sump flow rate that credit is taken in the safety analysis. The unidentified leakage rate limit is based, with an adequate margin for contingencies, so that corrective action could be taken before the

l integrity of the nuclear systert process barrier wculd be threatened. The extension of the calibration frequency to 24 months has been evaluated by GSU with Vendor ccncurrence and found not to reduce the margin of safety as previously analyzed. Calculations provide for a maximum trip setpoint of 4.7 gpm for a 24 month calibration interval. rue frequency given in the Technical Specifications of 18 months appears to be to support a nominal fuel cycle of 18 months. GSU has reviewed equipment, FSAR and Regulatory requirements as noted above, and the Standard Review Plan and SER which confirms that an extension to the Surveillance period is not in conflict to guidance or requirements of the Staff and vendors. In addition, the subject flow transmitters provide a signal to an alarm and indication only, there are no isolations or specific credit taken in the Safety Analysis for this instrument. A review of the operating history of the Drywell Air Coolers Drain Flow Systems confirms the reliability indicated by the above analysis, a functional test performed 14 times since January, 1986 has found satisfactory results on all occt.ssions. In addition, the drywell drain sump which receives the flow from the air coolers has been functionally, tested 15 times since January 1986 and feind within Technical Specification requirements on all occasions. 1

• SIGNIFICANT HAZARDS CONSIDERATION As discussed in 10CFR50.92, the following discussions are provided to support the NRC Staff in its determination of "no significant hazards considerations".

a. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the change in the surveillance interval will not result in a decrease in the required instrument accuracy. This position is supported by the purpose of this system is to alert and aid the operator in defining an event, no credit is taken in the Safety Analysis for the alarms for high drywell air cooler drain flow.

Operator action results from information received from the drywell sump flow not the air cooler condensate flow and therefore, the response to previously evaluated events will be unchanged. Since the revision does not involve a design, configuration or operational change to the plant and the response to events is unchanged. There is no increase in the probability or consequence of any accident previously evaluated.

b. The propcsed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the change in the frequency of calibration of the drywell air cooler drain flow indication will remain within the present design criteria and respond as previously evaluated and does not involve a design change or physical change, and therefore does not alter the design response of the instrumentation. Thus, no new accident scenario is introduced by this revised frequency of calibration of the acoustic monitors.

c. The proposed change to the acoustic monitors surveillance period does not involve a significant reduction in a margin of safety because the change in the frequency of calibration for the drywell air cooler drain flow indication is not used in the accident analysis and therefore no reduction in the analyzed margin of safety will be created. Additionally, as delineated in the justification, the proposed change will not effect the performance requirements in the Limiting Conditions of Operation contained in the Technical Specification. Thus, the margin of safety is not impacted.

This change is not considered, as stated above, to increase the probability or consequences of a previcusly analyzed accident or reduce safety margins, further the results of the change are clearly within an acceptable criteria with respect to the system of component specified in the Standard Review Plan. The basis for this conclusion is that calculated drift for the requested frequency will remain within the allowable value discussed in above. Therefore, the criteria for system performance as discussed in the FSAR have not been affected and continue to agree wit h the Standard Review Plan. Since the proposed amendment does not change any previously revised and approved description or analysis described in the FSAR, the proposed

• amendment does not create the possibility of a new or different type of accident, and the proposed change does not involve a significant reduction in a margin of safety. GSU proposes that no significant hazards considerations are involved.

REVISED TECHNICAL SPECIFICATION The requested revision is provided in the Enclosure. SCHEDULE FOR ATTAINING COMPLIANCE As indicated above, River Bend Station is currently in compliance with the applicable Techical Specification. This Technical Specification revision is required prior to September, 1987 to avoid a unit outage to conduct the required surveillance test as discussed above. NOTIFICATION OF STATE PERSONNEL A copy of the amendment application and this submittal has been provided to the state of Louisiana, Department of Environmental Quality - Nuclear Energy Division. ENVIRONMENTAL IMPACT APPRAISAL Revision of this Technical Specification does not result f.n an environmental impact beyond that previously analyzed. Therefore, the approval of this amendment does not result in a significant environmental impact nor does it change any previous environmental impact statements for River Bend Station. i

\ ~ ENCLOSURE i i I

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REACTOR COOLANT SYSTEM 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.3.1 The be OPERABLE: following reactor coolant system leakage detection systems shall a. The drywell atmosphere particulate radioactivity monitoring system, b. The drywell and pedestal floor sump drain flow monitoring systems, c. Either the drywell air coolers condensate flow rate monitoring system or the drywell atmosphere gaseous radioactivity monitoring system. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3. ACTION: With only two of the above required leakage detection systems OPERABLE, opera-tion may continue for up to 30 days provided grab samples of the drywell atmos-phere are obtained and analyzed at least once per 24 hours when the required gaseous and/or particulate radioactive monitoring system is inoperable; other-wise, be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours. SURVEILLANCE REQUIREMENTS 4.4.3.1 The reactor coolant system leakage detection systems shall be demon-strated OPERABLE by: a. Drywell atmosphere particulate and gaseous monitoring systems-performance of a CHANNEL CHECK at least once per 12 hours, a CHANNEL FUNCTIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION at least once per 18 months.

b. The isump drain flow monitoring systems performance of a CHANNEL j

FUNCTIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION T ast once per

c. Drywell air coolers condensate flow rate monitoring system-performance of a CHANNEL FUNCTIONAL TEST at east once per 31 days and a CHANNEL CALIBRATION at least once per months.

d. Flow testing the drywell floor drain sump inlet piping for blockage at least once per 18 months.* 1 "Not outage. required to be performed until prior to startup following first refueling RIVER BEND - UNIT 1 3/4 4-10

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