ML20080M942

Proposed Tech Spec Change 12,revising LER Sys

ML20080M942
Person / Time
Site:	Cooper
Issue date:	02/14/1984
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20080M936	List: ML20080M942 NLS8400060, Application for Amend to License DPR-46,consisting of Proposed Change 12,revising LER Sys
References
TAC-54247, NUDOCS 8402220032
Download: ML20080M942 (12)

Text

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Attachmtnt 1 Revised Technical Specifications for Licensee Event Report System Revised Pages: 216b 2161 231 iv 216c 221 232 216f 224 233 216g 228 234 Evaluation of this Revision with Respect to 10CFR50.92 NPPD has analyzed this proposed change and considers that it does not:

1. Involve a significant increase in the probability or consequences of an .

accident previously evaluated; or

2. Create the possibility of a new or different kina of accident from any accident previously evaluated; or

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

The District has made this determination on the basis that this is only a clarifying _ administrative change and falls under the example given by the commission in 48FR14870 for amendments that are considered not likely to involve significant hazards considerations. This example states, "A purely administrative change to Technical Specifications: For example, a change to achieve consiste'ncy throughout the Technical Specifications, correction of an error, or a change in nomenclature." The District also considers this a change in regulations and falls under the example given in 48FR14870. This example states, "A change to make a license conform to changes in regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations."

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" 8402220032 840214 PDR ADOCK 05000298 P PDR ,

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.~ s TABLE OF CONTENTS (Cont'd.)

Page No.

SURVEILLANCE LIMITING CONDITIONS FOR OPERATION REQUIREMENTS 6.2.1.B NPPD Safety Review and Audit Board (SRAB) 222 B.1 Membershir- 223 B.2 Meeting Frequency 223

-B.3 Quorum 223 B.4 Review .223 B.5 Authority 224.

B.6 Records 225 B.7 Procedures 225 B.8 Audits 225 6.3 Proceduces and Programs 226 6.3.1 Introduction 224 6.3.2 Procedures 226 6.3.3 Maintenance and Test Procedures :226 6.3.4 Radiation Control Procedures 226'

.A High Radiation Areas 226a 6.3.5 Temporary Changes 226a 6.3.6 Exercise of Procedures 226a 6.3.7 Programs 226a

.A Systems Integrity Monitoring Program 226a

.B Iodine Monitoring Program 226a

. .C Environmental Qualification Program 226a

' 6. 4 ' -Record Retention

• 228 6.4.1 5 year retention 228 6.4.2 Life retention 228 6.4.3 ,2 year retention 229 6.5 Station Reporting Requirements 230 6.5.1 Routine Reports 230

.A Introduction 230 ,

.B Startup Report .230

.C Annual Reports 230

.D Monthly Operating Report 231 6.5.2 Reportable Events _

'231 l 6.5.3- Unique Reporting Requirements 235 L6.6 Station Operating Records 228 6.6.1 (5 year retention) 228 6.6.2 (life retention) 228 6.6.3 (2 year retention) 229

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.' s LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

. 3.14 FIRE DETECTION SYSTEM 4.14 FIRE DETECTION SYSTEM APPLICABILITY APPLICABILITY Applies to'the operational status of the Applies to the operational status of the Fire Detection System. Fire Detection System.

03JECTIVE-To assure continuous automatic surveillance throughout the Main Plant.

SPECIFICATIONS SPECIFICATIONS ,

A. The Fire Detection System instumen- A. Each detector on Table 3.14 shall be tation for each fire detection zone - demonstrated operable every 6 months ishown in Table 3.14 shall be operable. by performance of a channel functional test.

B. With one or more of the fire detection B. The NFPA Code 72.D. Class B supervised instrument (s) shown in Table 3.14 circuits supervision associated with inoperable: the detector alarms of each of the above required fire detection

1. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire instruments shall be demonstrated

- watch patrol to inspect the OPERABLE at least once per 6 months.

zone (s) with the inoperable instru- '

ment (s) at least once per hour, and ,

2. Restore the inoperable instrument (s) to OPERABLE status within 14 days or prepare and submit a Special l Report to the Commission within the next 30 days outlining the action

! taken, the cause of the inoperability and the plans and schedule for re-

• storing the instrument (s) to OPERABLE status.

3.15 FIRE SUPPRESSION WATER SYSTEM 4.15 FIRE SUPPRESSION WATER SYSTEM APPLICABILITY APPLICABILITY Applies to the availability of water for fire fighting' purposes. Applies to the availability of water for fire fighting purposes.

OBJECTIVE

-To assure a continuous operable water supply for fire fighting syste'ms from 2 fire pumps.

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS

'3.15 (cont'd) 4.15 (cont'd) ,

SPECIFICATIONS SPECIFICATIONS A. _The fire suppression water system shall A. The Fire Suppression Water Supply be OPERABLE with: System shall be demonstrated operable:

1. Two fire pumps, each with a capacity 1. At least once per 31 days by j of at least 2000 gpm, with their starting each pump on a stag-discharge aligned to the fire, gered start-up basis and operating suppression header. it'for:

i b

2. An OPERABLE flow path capable of a) A minimum of 15 minutes

taking suction from either of two for a diesel engine-driven ,

500,000 gallon water storage tanks fire pump, and i

, or the Missouri River and transferring the water through b) A minimum of 7 minutes for distribdtion piping with OPERABLE ^

an electrical motor-driven

sectionalizing control or isolation' fire pump.

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-valves co~the yard hydrant valves and.the front valve ahead of the 2. At least once per 31 days by water flow alarm device on each verifying that each valve

sprinkler, hose standpipe or spray (manual, power operated.or system. riser._ automatic) in the flow path that is not locked, sealed or

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F 'B. If the requirement of 3.15. A cannot be . otherwise secured in position,

. . met, restore the inoperable equipment is in its correct position.

to OPERABLE status within 7 days or

. prepare and submit'a Special-Report to 3. At least once per 12 months by l

-the Commission within the next 30 days , cycling each testable valve in

, outlining the plans and procedures to the flow path through at least be used to provide for the loss of_ one complete cycle of fulli redundancy in this system.--

travel.

l, C. With the fire suppression system in- 4. At least once per 18 months by performing a system functional operable: -

test which includes simulated

1. . Establish'a backup fire suppression automatic actuation of the i water system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and system throughout its operating sequence, and:

l 2. . Submit a.Special Report:

a) Verifying that each auto-

~ a) .By' telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and matic valve in the flow path actuates to its correct.

F b) In writing no later than the position on a test signal, first working day following the event, outlining the action taken, b) Verifying that each pump the cause of the inoperability and developes at least 2000 gpm with ,

the plans and schedule for restor- at least 110 psi, ing the system to OPERABLE status.

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-LIMITING CONDITIONS FOR OPERATION hDRVEILLANCEREQUIREMENTS 3.16 (cont'd) 4.16 (cont'd)

SPECIFICATIONS SPECIFICATIONS A. The Automatic Sprinkler Systems protect- A. The Automatic Sprinkler Systems protect--

ing the Cable Spreading Room, Cable ing the Cable Spreading Room, Cable Expansion Room, and Northeast Corner - Expansion Room, and Northeast Corner -

903 Ft. Elev. of Reactor Building shall 903 Ft. Elev. of Reactor Building shall be operable. be demonstarted to be operable by:

B. If the requirement of 3.16.A cannot be 1. At least once per 12 months by met, establish a continuous fire watch cycling each testable valve in the with backup fire suppression equipment flow Path through at least one for the unprotected area within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; complete cycle of full travel.

restore the system to OPERABLE status within 14 days or prepare and. submit a 2. At least once per 18 months:

Special Report to the Commission l within the next 30 days outlining a) By performing a system func-the action taken, the cause of the tional test which includes inoperability and the plans and simulated automatic actua-schedule for restoring the system tion of tne system, and to OPERABLE status. 1) Verifying that the auto-matic valves in the flow path actuate to their correct positions on a test signal, and

2) Cycling each valve in the flow path that is not testable during plant ooeration through at least one complete cycle of full travel.

b) By inspection of the spray headers to verify their integrity.

3.17 CARBON DIOXIDE SYSTEM 4.17 CARBON DIOXIDE SYSTEM APPLICABILITY APPLICABILITY Applies to the operational status of the High Applies to the operational status of the Higi Pressure Carbon Dioxide Extinguishing System Pressure Carbon Dioxide Extinguishing System protecting the Diesel Generator Rooms. protecting the Diesel Generator Rooms.

OBJECTIVE

.To assure continuous Automatic Fire' Protection for the Diesel Generator Rooms.

SPECIFICATIONS SPECIFICATIONS A. The High Pressure Carbon Dioxide Extin- A. The High Pressure Carbon Dioxide Extin-guishing System protecting the Diesel guishing System protecting the Diesel Generator Rooms shall be operable. Generator Rooms shall be demonstrated operable by:

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• LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.17 (cont'd) 4.17 (cont'd)

B. If the requirement of 3.17.A cannot 1. At least once per 6 months, be met: the High Pressure Carbon Dioxide storage cylinders should be

1. Establish a continuous fire watch weighed.

with backup fire suppression equip-ment for the unprotected area (s) 2. At least once per 18 months by within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; restore the system verifying the system valves, to OPERABLE status within 14 days alarms, and associated venti-or prepare and submit a Special lation motor interlocks and l Report to the Commission within dampers actuate to a simulated the next 30 days outlining the automatic and manual actuation action taken, the cause of the signal. A brief air flow test inoperability and the plans and (" Puff Test") shall be made to schedule for restoring the verify flow from each nozzle.

system to OPERABLE status.

3.18 FIRE HOSE STATIONS 4.18 FIRE HOSE STATIONS APPLICABILITY APPLICABILITY Applies to the operational status of the Fire Hose Stations in the Control and Applies to the operational status of the Reactor Buildings. Fire Hose Stations in the Control and Reactor Buildings.

OBJECTIVE To assure continuous manual fire fighting '

capability provided by existing Fire Hose Stations.

SPECIFICATIONS i SPECIFICATIONS A. ~ The Fire Hose Stations shown in Table 3.18 shall be operable. A. The Fire Hose Stations in the Control Building and Reactor B. If the requirement of 3.18.A cannot Building shall be demonstrated be met, route an additional hose to to be operable by:

the area protected by the inoperable Fire Hose Station from an operable 1. At least once per 31 days by:

Fire Hose Station of equivalent capacity within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. a) Visual inspection to assure all required equipment is at the station.

2. At least once per 18 months by:

a) Removing the hose for inspection and re-racking, and b) Replacement of all degraded gaskets in couplings.

3. At least once per 3 years by:

a) Partially opening each hose station valve to verify valve OPERABILITY and no flow

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LIMITING CONDITIONS FOR OPERATION ' SURVEILLANCE REQUIREMENTS

~3.20 YARD FIRE HYDRANT AND HYDRANT HOSE 4.20 YARD FIRE HYDRANT AND HYDRANT HOSE HOUSE

.-HOUSE APPLICABILITY APPLICABILITY Applies to the operational status of the Applies to the operational status of the yard

. yard fire hydrant, HT-1 and associated fire hydrant, HT-1, and associated hydrant hydrant hose house located near the north- hose house located near the northwest corner west corner of the Intake-Structure, of the Intake Structure.

l OBJECTIVE To assure continuous manual fire fighting capability for the fire water pumps and

' service water pumps .in the Intake Structure provided by the existing yard fire hydrant, *

-HT-1, and the associated hydrant hose house.

j. SPECIFICATIONS SPECIFICATIONS A. Yard fire hydrant HT-1 and its associ- A. Yard fire hydrant HT-1 and associated

, ated hydrant hose house shall be hydrant hose house shall be demo'nstrated

!- operable. operable:

B. If the requirement of 3.20A.cannot be 1. At least once per 31 days by:

met, provide sufficient additional lengths of 2 inch diameter hose a) Visually inspecting the hydrant hose

' . located in an adjacent operable hydrant house to assure all required equipment:

hose house to provide service to the is at the hose house, unprotected arec within one hour, if the

! inoperable fire hydrant or associated 2. At least; once per six months (once during i hydrant hose house is the. primary means March, April or May and once during 1-of fire suppression; otherwise provide September, October or November) by:

'. the additional hose within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Restore the hydrant or hose house to a) Visually inspecting the yard fire operable status within 14 days or hydrant'and verifying that the hydrant:

prepare and submit a Special Report to barrel is dry and that the hydrant is l the Commission within.the next 30 days not damaged.

! . outlining the~ action taken, the cause of the inoperability and the plans and 3. At least once per 12 months by:

) schedule for restoring the hydrant or hose house to operable status, a) Conducting a hose hydrostatic test at a pressure at least 50 psig greater !

than the maximum pressure available at the yard fire hydrant.

b) Inspecting'all the gaskets and replacing any degraded gaskets in the couplings.

j c) Performing a flow check of the i

hydrant to verify its operability.

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r 6.2 (cent'd)

f. Investigate all reported instances of violations of. Technical Specifications, including reporting evaluation and recommendations to prevent recurrence, to the Division Manager of Power Operations and to the Chairman of the NPPD Safety Review and Audit Board.

g. Perform special reviews and investigations and render reports thereon as requested by the Chairman of the Safety Review and Audit Board.

h. Review all reportable events specified in Section 50.73 to 10CFR I Part 50.

1. Review drills on emergency procedures (including plant evacuation) and adequacy of communication with off site groups.

'j. Periodically review procedures required by Specifications 6.3.1, 6.3.2, 6.3.3, and 6.3.4 as set for.th in administrative procedures.

. 5. Authority

a. The Station Operations Review Committe shall be advisory.

b. The Station Operations Review Committee shall recommend to the Station Superintendent approval or disapproval of proposals under items 4, a through e and j above. In case of disagreement between the recommendations of the Station Operations Review Committee and the Station Superintendent, the course determined by the Station Superintendent to be the more conservative will be followed. A written summary of the disagreement will be ,

sent to the Division Manager of Power Operations and to the NPPD' Safety Review and Audit Board,

c. The Station Operations Review Committee shall report to the Chairman of th: NPPD Safety Review and Audit Board on all re-views and investigations conducted under items 4.f, 4.g. 4.h.

and 4.1.

d. The Station Operations Review Committee shall make tentative determinations regarding whether or not proposals considered by the Committee involve unreviewed safety questions. This determination shall be subject to review and approval by the NPPD Safety Review and Audit Board.

6. Records:

Minutes shall be kept for all meetings of the Station Operations Review Committee and shall include identification of all documen-

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- 6. 2 (cont'd)

c. Proposed tests or experiments which involve an unreviewed safety question as definad in Section 50.59, 10 CFR.

d. Proposed changes to Appendix A Technical Specifications or this Operating License,

e. Violations of applicable codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance,

f. Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

g. All reportable events specified in Section 50.73 to 10CFR Part 50.

h. .Any indicaticn of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems, or components.

1. Minutes of meetings of the Station Operations Review Committee.

J. Disagreement between the recommendations of the Station Operations Review Committee and the Station Superintendent.

k. Review of events covered under e,f,g, and h above include reporting to appropriate members of management on the results of investiga-tions and recommendations to prevent or reduce the probability of recurrence.

5. Authority: The NPPD Safety Review and Audit Board shall be advisory to the General Manager and.shall have authority to:

a. Approve proposed changes to the operating license including Technical Specifications and Safety Analysis Report for submission to the NRC.

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7 6.4 RECOPD RETENTION 6.4.1 5 Year Retention Records and/or logs relat!ve to the following items shall be kept in a manner convenient for review and shall be retained for at least 5 years l unless a longer period is required by applicable regulations.

A. Records of normal station operation, including power levels and periods of operation at each power level.

B. Records of periodic checks, inspection and/or calibrations performed ,

to verify that Surveillance Requirements are being met.

i C. Records of principal maintenance activities, including inspection, repair, substitution or replacement of principal items of equipment

pertaining to nuclear safety.

l D. Records of reportable events as specified in 6.5.2.

E. Record of changes to plant procedures.

F. Records of special tests and experiments.

G. Records of wind speed and direction.

, 6.4.2 Life Retention

. Records and logs relating to the following items shall be kept for the life of the plant.

A. Records of changes made to the station as described in the Safety Analysis Report and amendments and reflected in updated, corrected and as-built drawings and records.

i B. Records of new and spent fuel invent'ory and assembly histories.

C. Records of station radiation and contamination surveys.

D. Records of off-site environmental monitoring surveys.

E. Records of radiation exposure for all station personnel, including all contractors and visitors to the station in accordance with 10 CFR 20.

F. Records of radioactivity in liquid and gaseous wastes released to

the environment.

G.- Design Fatigue Usage Evaluation

1. Monitoring, recording, and evaluation will be met for various portions of the reactor coolant pressure boundary l

-(RCPB) for which detailed fatigue r

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1. A tabulation on an cnnual basic of tha numbar of otation, utility and other personnel (including contractors) re-ceiving exposures greater than 100 mrem /yr and their associated man rem exposure according to work and job functions, 1/ e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special main-tenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures totaling less than 20%

of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total whole body dose

. received from external sources shall be assigned to specific major work functions.

2. A summary description of facility changes, tests or experi-ments in accordance with the requirements of 10CFR50.59(b).

3. Pursuant to 3.8. A. a report of radioactive source leak testing. This report is required only if the tests reveal the presence of 0.005 microcuries or more of removable contamination.

D. Monthlv Operating Report Routine reports of operating statistics, shutdown experience, and a narrative summary of operating experience relat'ing to safe operation of the facility, shall be submitted on a monthly basis to the individual designated in the current revision of Reg.

Guide 10.1 no later than the tenth of each month following the calendar month covered by the report.

6.5.2 Reportable Events A Reportable Event shall be any of those conditions specifed in Section 50.73 to 10CFR Part 50. The NRC shall Le notified and a report submitted pursuant to the requirements of Section 50.73.

Each Reportable Event shall be reviewed by SORC and the results of this review shall be submitted to SRAB and the Assistant General Manager - Nuclear.

1/ This tabulation supplements the requirements of $20.407 of 10CFR Part 20.

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