ML17305B508

Application for Amends to Licenses NPF-41,NPF-51 & NPF-74, Adding Footnote to Tech Spec 4.3-8 Re Radioactive Gaseous Effluents Monitoring Instrumentation Requirements

ML17305B508
Person / Time
Site:	Palo Verde
Issue date:	04/30/1991
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17305B510	List: ML17305B508 ML17305B511
References
161-03920-WFC-D, 161-3920-WFC-D, NUDOCS 9105070316
Download: ML17305B508 (13)

Text

ACCELERATED DISTRIBUTION DEMONST$&TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9105070316 DOC.DATE: 91/04/30 NOTARIZED: YES DOCKET g FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAY,W.F. Arizona Public Service Co. (formerly Arizona Nuclear Power R RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) I

SUBJECT:

Application for amends to licenses NPF-41,NPF-51 & NPF-74, D adding footnote to Tech Spec 4.3-8 re radioactive gaseous effluents monitoring instrumentation requirements.

DISTRIBUTION CODE: A009D COPIES RECEIVED:LTR TITLE: OR/Licensing Submittal: Appendix I 1 ENCL / SIZE: +/~

NOTES:STANDARDIZED PLANT 05000528 A Standardized plant. 05000529 Standardized plant. 05000530 D D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 TRAMMELL,C 2 2 THOMPSON,M 2 2 INTERNAL: ACRS 3 3 NRR/BRADFUTE,J 1 1 NRR/DREP DIR10E 1 0 NRR/DREP/PRPBll 1 1 NUDOCS-ABSTRACT 1 1 OC ~E~9~. 1 0 OGC/HDS1 1 0 G<BZL 1 1 RGN5 DRSS/RPB 1 1 EXTERNAL EGGG AKERS E D 1 1 NRC PDR 1 1 PNL/BAKERS D A 1 1 NOTES: 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 18

0 r>

~

f

Arizona Public Service Company P.O, BOX 53999 ~ PHOENIX, ARIZONA85072<999 WILLIAMF. CONWAY 161-03920-WFC/DAF EXECUTIVEVICE PRESIDENT NUCLEAR April 30, 1991 Docket Nos. STN 50-528/529/530 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37 Washington, D.C. 20555

Dear Sirs:

Subj ect: Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Proposed Technical Specification Change to Table 4.3-8, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements File: 91-056-026; 91-005-419.5 In accordance with 10 CFR 50.90, Arizona Public Service Company (APS) submits herewith a request to amend Facility Operating Licenses NPF-41, NPF-51, and NPF-74, for PVNGS Units 1, 2, and 3 respectively. The proposed amendments add a footnote to Technical Specification Table 4.3-8, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements, to allow the use of light emitting diodes as check sources for four noble gas activity monitors.

The enclosure to this letter includes:

A. Description of Proposed Technical Specification Amendment Request B. Purpose of the Technical Specification C. Need for the Technical Specification Amendment D. Safety Analysis for the Proposed Change E. No Significant Hazards Consideration Determination F. Environmental Impact Consideration Determination G. Marked-Up Technical Specification Change Pages Pursuant to 10 CFR 50.91(b)(1), a copy of the proposed amendment is being forwarded to the Arizona Radiation Regulatory Agency.

<DR 9i05070316 910430

,PDR ., ADOCK P

05000528

161-03920-WFC/DAF April 30, 1991 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Proposed Tech. Spec, Change to Table 4.3-8 Page Two If you should have any questions, please contact Michael E. Powell of my staff at (602) 340-4981.

Sincerely, WFC/DAF/rw Enclosure cc: J. B. Martin D. HE Coe A. C. Gehr A. H. Gutterman C. F. Tedford

161-03920-WFC/DAF April 30, 1991 STATE OF ARIZONA )

) ss.

COUNTY OF MARICOPA )

I, W. F. Conway, represent that I am Executive Vice President Nuclear, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true and correct.

W. F. Conway Sworn To Before Me This ~ Dey Of 1991.

Public

~ h My Commission Expires

,I

'I 1

l I

161-03920-NFC/DAF April 30, 1991 ENCLOSURE A. DESCRIPTION OF PROPOSED TECHNICAL SPECIFICATION AMENDMENT RE VEST The proposed amendment, revises Technical Specification Table 4.3-8, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements. The revision adds a footnote to the noble gas activity monitors to allow the use of light emitting diodes (LED) as check sources.

Four Technical Specification noble gas activity monitors (RU-12, RU-141, RU-143 and RU-145) have built-in LED check sources. The proposed amendment would allow the use of the built-in LED check sources as an acceptable method for verifying a qualitative channel response to assess detector operability for these four monitors. The proposed footnote reads, "LED may be utilized as the check source in lieu of a source of increased radioactivity."

B. PURPOSE OF THE TECHNICAL SPECIFICATION The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents. The alarm/trip setpoints for these instruments are required to be calculated and adjusted in accordance with the methodology and parameters specified in the Offsite Dose Calculation Manual (ODCM) to ensure that the limits of 10 CFR Part 20 are not exceeded.

C. NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT This Technical Specification amendment is needed to permit the use of the built-in LED check sources for four Technical Specification noble gas activity monitors. Currently, the use of the LED check sources is not permitted under the literal interpretation of the SOURCE CHECK definition (Technical Specification 1.33), which requires the channel sensor to be exposed to a source of increased radioactivity. However, the use of LED check sources is consistent with the detector vendor manual which states, "The LED check source, when activated by an operator, makes it possible to confirm the detector's operability."

D. SAFETY ANALYSIS FOR THE PROPOSED CHANGE The use of LED check sources is consistent with the detector vendor manual which states, "The channel is composed of a volumetric chamber, into which the gases are pumped, that is surrounded by thick lead shielding. Also enclosed within the shield are a beta scintillator with a LED (light emitting diode) check source, and a preamplifier. The LED check source, when activated by an operator, makes it possible to confirm the detector's operability." However, to determine any distinguishing characteristics between LED and isotopic check sources for qualitatively assessing detector operability, as required by the Technical Specifications, APS has

161-03920-MFC/DAF April 30, 1991 evaluated potential detector failure mechanisms. Those failure mechanisms considered credible are failures of the active detector components (photomultiplier tube, preamplifier, cabling, microcomputer, and high voltage power supply).

These failures would be detected equally well by both the LED and radioactive check source methods. Furthermore, use of LED check sources satisfies the Technical Specification source check requirements.

Therefore, the use of the LED in lieu of an isotopic check source does not involve an unreviewed safety question.

NO SIGNIFICA H Z 0 SIDERATION DETERMINATION The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

A discussion of these standards as they relate to the amendment request follows:

consequences of an accident previously evaluated.

The proposed amendment permits the use of the built-in LED check sources for Technical Specification monitors RU-12 (Gaseous Radwaste System Noble Gas Activity Monitor), RU-141 (Condenser Evacuation System Noble Gas Activity Monitor), RU-143, (Plant Vent System Noble Gas Activity Monitor) and RU-145 (Fuel Building Ventilation System Noble Gas Activity Monitor). The vendor manual states, "The LED check source when activated by an operator, makes it possible to confirm the detector's operability." Use of the LED check sources provides an alternative method for the qualitative assessment of channel response for these four noble gas activity monitors and does not change the source check requirement nor surveillance interval.

The credible failure mechanisms of beta scintillator detectors (i.e., failure of the photomultiplier tube, preamplifier, cabling, microcomputer, and high voltage power supply) would be detected with equal confidence by the LED or isotopic check sources. The use of LED check sources does not affect assumptions contained in plant safety analyses, nor does the use affect Technical Specifications that preserve safety analysis assumptions. Therefore, the proposed amendment does not affect the probability or consequences of accidents previously evaluated.

l, 161-03920-WFC/DAF April 30, 1991 STANDARD 2 -- Create the possibility of a new or different kind of accident from any accident previously evaluated.

This proposed amendment permits the use of LED check sources in lieu of isotopic check sources, but does not change the intent of the Technical Specification requirements. The LED check sources qualitatively assess the detector channel response. Use of LED check sources does not alter the design of the facility nor the operation of the detectors. There are no credible failures of the detectors that would not be detected with equal confidence by the LED or isotopic check sources. Therefore, failure mechanisms of the monitors remain unchanged, and hence the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

STANDARD 3 -- Involve a significant reduction in a margin of safety.

The proposed amendment, permitting the use of LEDs in lieu of isotopic check sources, makes no changes to safety limits, setpoints, or design margins at PVNGS and, therefore, does not involve a significant reduction in a margin of safety.

F. ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed amendment allows the use of LED check sources in lieu of a source of increasing radioactivity as required by Technical Specification 1.33, for the qualitative assessment of channel response for four noble gas activity monitors. The LED check sources for these four monitors are built-in and were originally supplied from the vendor in that configuration. The vendor manual states, "The LED check source, when activated by an operator, makes it possible to confirm the detector's operability." Use of the LED check sources provides an alternative method for the qualitative assessment of channel response for these four noble gas activity monitors and does not change the source check requirement nor surveillance interval. The proposed amendment does not alter the plant configuration nor does it change the way the plant is operated.

APS has determined that the proposed amendment: involves no change in the amount, nor type of any effluent that may be released offsite, and that there is no increase in individual or cumulative occupational radiation exposure. As such, operation of PVNGS Units 1, 2, and 3, in accordance with the proposed amendment, does not involve an unreviewed environmental safety question.

G. MARKED-UP TECHNICAL SPECIFICATION CHANGE PAGES See attached pages 3/4 3-69 through 3/4 3-72 for Units 1, 2, and 3.

1