ML20056F764

LAR Requesting Exercise of Enforcement Discretion from Requirement to Perform Channel Check on Narrow Range RWST low-low Level Transmitters

ML20056F764
Person / Time
Site:	Seabrook
Issue date:	08/26/1993
From:	Deloach R NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20056F763	List: ML20056F762 ML20056F764 ML20056F767
References
NUDOCS 9308310021
Download: ML20056F764 (3)

Text

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t North Atlantic August 26,1993 4

i ENCLOSURE 2 TO NYN-93119  ;

LICENSE AMENDMENT REQUEST 93-10 i

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PDR ADOCK 05000443

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, SEABROOK STATION UNIT 1 ircminilAtlantic Energy Service Corporation  ;

Facility Operating License NPF-86 Docket No. 50-443 License Amendment Request No. 93-10 Change to Technical Specification 4.3.2.1 This License Amendment Request is submitted by North Atlantic Energy Service Corporation pursuant to 10CFR50.90. The following information is enclosed in support of this License Amendment Request:

Section 1 -

Introduction and Description of Proposed Changes Section 11 -

Markup of Proposed Changes Section ill -

Retype of Proposed ChangesSection IV -

Determination of Significant Hazards for Proposed Changes  :

Section V -

EnvironmentalImpact Assessment i

Sworn and Subscribed to before me this 1 cd day of //RS/n:t- ,1993

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?//h/ b,. f$tf TV (.) R. Jeb DeLoach l N

y otary Public Executive Director - Engineering & Licensing TRACY A. D3CPUC'S Ucry P;Mc My comm! won Deac; Ozur 3,1??5

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L INTRODUCTION AND DESCRIPTION OF PROPOSED CHANGES In Enclosure 1, North Atlantic Energy Service Corporation (North Atlantic) requested the exercise of enforcement discretion from the requirement to perform a CHANNEL CHECK on the narrow range Refueling Water Storage Tank (RWST) low-low level transmitters. In the request, North Atlantic ,

proposed to replace the requirement for performing a CHANNEL CHECK pursuant to Technical  :

Speci6 cation 4.3.2.1, Table 4.3-2, Functional Unit 8b, with a requirement to perform a TRIP ACTUATING DEVICE OPERATIONAL CHECK (TADOT) at least once per 92 days.  ;

North Atlantic requested the exercise of enforcement discretion and proposed the enclosed changes to

' Technical Speci6 cation 4.3.2.1 because it has been determined that the existing plant design does not allow a CllANNEL CllECK to be performed that meets the intent of a CHANNEL CHECK, as denned in Technical Speci6 cation 1.6, without imposing testing requirements that are inappropriate for the existing plant conditions and which also may increase the risk of a plant transient involving a premature switchover to the containment sump. North Atlantic has requested that this License Amendment Request (LAR) be a processed on an exigent basis for the reasons provided in the attached request for exercise of enforcement l discretion. l In summary, New llampshire Yankee, North Atlantic's predecessor, made an error by certifying and accepting the requirement for a CHANNEL CHECK in Technical Speci6 cation 4.3.2.1, Table 4.3-2,  ;

Functional Unit 8.b. This Technical Speci6 cation is designed for a standard plant that has wide range  ;

transmitters for the Refueling Water Storage Tank (RWST) low-low level point and that also has remote 1

or local indication of RWST level. Seabrook Station is designed with narrow range RWST low-low level  ;

4 transmitters and is not equipped with either remote or local indication of RWST level. >

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At Seabrook Station it is not possible to perform a CHANNEL CHECK of the RWST low-low level d

transmitters that meets the intent of the Technical Speci6 cations and at the same time does not impose a significant operational burden upon the Station Staff with no significant safety benent. In fact, with the Seabrook Station design it is preferable to not perform the CHANNEL CHECK, as described in Enclosure  ;

1, because there is a potential for damage to plant equipment, placing the plant in a condition that is not  ;

the safest possible. ,

On August 24,1993, Nonh Atlantic detemiined that the requirements of a CHANNEL CHECK had not .

been adequately performed in the past. The inadequate surveillance performance was classi6ed as a  ;

missed suncillance and an operational check of the four RWST low-low level channels was performed on August 24, 1993 pursuant to Technical Speci6 cation 4.0.3. This non-compliance with Technical Specifications will be documented in a Licensee Event Repon that will be submitted to the NRC by I September 23,1993 pursuant to 10CFR50.73.

An operability check procedure was performed on August 24,1993 to verify the operability of the RWST ,

low-low level instruments and to meet the intent of the CHANNEL CHECK. The procedure involves venting the level instrument and verifying that the empty alarm is actuated and that the transritter is accurate at the zero level. The performance of this surveillance takes approximately 7 ma+t.ours to complete and exposes personnel to increased radiation exposure (approximately 2 mrem per vnonnance  ;

or 850 mrem total if performed until the next refueling outage) and has the potential to have eersonnel contaminated with radioactive water due to the draining and venting processes of the procedure. In addition, this surveillance is intrusive into the system as it requires venting while the channel is placed  ;

in a tripped condition. The surveillance unduly exercises plant equipment which over the long run may  :

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mn may cause premature end oflife and may contribute to a plant transient. An evolution such as this -

also provides greater opportunity for operator error and is thus less safe than not performing the CIIANNEL CIIECK. The performance of this procedure every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to satisfy the current CIIANNEL CliECK requirement imposes an unnecessary operational burden on North Atlantic without any l commensurate increase in safety. t

.i Therefore, not withstanding the fact that an error was made in certifying the Technical Specifications in l 1986, North Atlantic has requested the NRC to exercise enforcement discretion regarding the performance ,

of the CilANNEL CllECK and to process this LAR on an exigent basis to eliminate testing that is burdensome and inappropriate for the existing plant conditions.

Description of Pronosed Chances

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1. Technical Specification 4.3.2.1 Table 4.3-2. Functional Unit 8b [page 3/4 3-34] is revised by l deleting the rquirement to perform a CliANNEL CllECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and by adding a new requirement to perform a TADOT at ieast once per 92 days. A note (3) is included l in the TADOT entry. The note clarifies that setpoint verification is not applicable to this TADOT. }

nis note is added because the setpoint verification function is already performed basis by the performance of the ANALOG CllANNEL OPERATIONAL TEST (ACOT). The ACOT will  !

continue to be performed as required by the current Technial Specifications with the approval of this amendment request. Performance of the TADOT will verify OPERABILITY of alarm i function by verifying that the associated alarm points do alarm but will not verify that the alann points alarm at a designated setpoint. Use of the notation for this application is consistent with Technical Specification 4.3.2.1, Table 4.3-1, Functional Unit 16a and 16b.

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2. Technical Specification -4.3.2.1, Table 4.3-2, Table Notation, [Page 3/4/3-35] is revised by adding notation (3). Notation (3) is applicable to the proposed requirement to perform a quarterly  !

TADOT on the narrow range RWST level transmitters, Functional Unit 8b. The notation states  !

"Setpoint verification is not applicable" r i

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