ML20080F798

Proposed Tech Specs Re Amends to Allow Analog Channel Operational Test Interval for Radiation Monitoring Instrumentation to Be Increased from Monthly to Quarterly

ML20080F798
Person / Time
Site:	McGuire, Mcguire
Issue date:	01/18/1995
From:	DUKE POWER CO.
To:
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ML20080F796	List: ML20080F790 ML20080F798
References
NUDOCS 9501310143
Download: ML20080F798 (13)

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ATTACHMENT 4 '

PROPOSED TECHNICAL SPECIFICATION AMENDMENTS FOR MCGUIRE i i

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9501310143 950118 PDR. ADOCK 05000369 P

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3 TABLE 4.3-3

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5 RADIATION MONITORING INSTRUMENTATION FOR PLANT g OPERATIONS SURVEILLANCE REQUIREMENTS

[ ANALOG 5 CHANNEL MODES g CHANNEL CHANNEL OPERATIONAL REQUIRING y MONITOR CHECK CALIBRATION TEST SURVEILLANCE k 1. Containment Atmosphere S R -M-Q 1,2,3,4 l g Gaseous Radioactivity-High (Low Range-EMF-39)

2. SpentFuelPooledikat.YiOG 5 R **

Radioactivity-High

-M-Q l (EMF-42) ..

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3. Criticality-High Radiation Level S R +Q

• l ta (Unit 1 - IEMF-17 and h Unit 2 - 2 EMF-4)

4. Gaseous Radioactivity-RCS Leakage Detection S R +Q 1,2,3,4 l (Low Range-EMF-39)

5. Particulate Radioactivity-S R CQ 1,2,3,4 l

RCS Leakage Detection (Low Range-EiiF-38) 1 1:

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M m 1 RADIATION MONITORING INSTRUMENTATION FOR PLANT

. OPERATIONS SURVEILLANCE "QUIREMENTS ANALOG

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• CHANNEL MODES.

• CHANNEL CHANNEL OPERATIONAL REQUIRING-MONITOR CHECK CALIBRATION TEST SURVEILLANCE

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6. Contr#' Room Air Intake Radioactivity-S R +Q All -l High (EMF-43a and EMF-43b)

TABLE NOTATION g -

With fuel in the fuel handling area.

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With irradiated fuel in the fuel handlipg area.

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SELECTED PAGES FROM NUREG-1366 AND GENERIC LETTER 93-05

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NUREG-1366 Imarovements to Technical Specifications l Surveillance Requirements .

i Manuscript Completed: May 1992 D te Published: December 1992 R. Lebel, T. R. Tpder Division of Operational Events Assessment Omce of Nuclear Reactor Regulation ,

U.S. Nuclear. Regulatory Commission ,

Washington, DC 20555 4 '

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. l ABSTRACT In August 1983 an NRC task group was fortned to investi- (ISIP) was established in December 1984 to provide the gite problems with surveillance testing required by framework for rewriting and improving the Technical Technical Specfications, ar.d to recommend approaches Specfications. As an element of the TSIP, all Technical to effect improvements. NUREG-1024 (" Technical Specfications surveillance requirements were compre-Specifications-Enhancing Safety Impact") resulted, and henstvely examined as recomme.nded in NUREG-1024.

it contained recommendations to review the basis for test The results of that effert are presented in this report.The frequencies; to ensure that the tests promote safety and study found that while some testing at power is essential do not degrade equipment; and to review surveillance to venfy equipment and system operability, safety can be tests so that they do not unnecessanly burden personnel, improved, equipment degradation decreased, and unnec-essary personnel burden relaxed by reducing the amount The Technical Specifications improvement Program of testing at power.

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surbine valves from every 7 days to every 31 days for North Anna Power Station. Unit 1. The capability to source check provides an integral vertfi-cation of the response of the detector. Dis is generally required monthly or before using a system that would Another factor in this case is the turbine manufacturers' release potentially radioactive fluid.

recommendations about the testing frequency of these valves. In some cases, these frequencies are comparable to the existing Technical Specifications. De testing of radiation monitors produces a significant number of isolations of the control coom, fuel handling De NRC staff recommends that, where the turbine .

building, auxiliary buildings, and various process lines. In manufacturer agrees, the testing interval for turbtne addition, the testing requires significant licensee staff.

valvc as part of the turbine overspeed protection system Licensees also stated that the frequent testing tends to surveillances be extended from weekly and monthly tests degrade the equipment. De instrumentation enust be to one test done quarterly, in which a direct visual obser- removed from cabinets and reinserted A mapnty of the vation will be made of the movement of each of the nstrumentation is self-checking so that most failures will turbine valves currently required by Technical Specifica- be found in this way or by channel checks.

tions to be tested.

The San Onofre licensee proposed that the surveillance A quarterly test corresponds to the most stringent valve test intervals for radia'. ion monitors be extended. De-testing requirement of the ASME Code. tailed information on failure history was provided for some monitors. In addition, the San Onofre licensee Findings made the following points in support of the extension of the surveillance test intervah De radiatica monitors at e Turbine overspeed testing requires a reduction in San Onofre have had a muumal failure history.'De fail-power and is a main cause of reactor trips during ures are normally of remote m eter indiction which would testing

• not impact the safety function. In addition, channel checks ano failure alarms would detect failures that rea e Testing of the turbine valves is necessary and the "'

manufacturers' recommendations should be fol-lowed.

De extent to wiuch these points are generic has no; been -

determined as part of this study. It is, therefore, difficult Recommendation to take the San Onofre experience and~ design and to Where the turbine manufacturer agrees, the turbine ex'.rapolate it to other reactor sites. his appears to be a situation in which reliability-based Technical Specifica-valve testing frequency should be changed to quarterly. tions surveillance requirements could be utilized to de- 1 y

crease the frequency of surveillance testing on reliable radiatior. monitoring systems while requiring more fre-5.14 Radiation Monitors (PWR, BWR) quent testing on radiation monitors that are not as reh-able.

The Technical Specxfications contain thrge categories of radiation monitors those used for gaseous and liquid effluent monitoring, those used for monitoring an area It does seem reasonable to give relief on the frequency of and indicating the radiation level, and those that are part ,

channel functional tests since these tests do not involve of the reactor protection system and engineered safety the sensor (radiation monitor)itself Therefore, in order features actuation systems. De only radiation monitors to decrease the 8icensee burden and increase the avril-with a reactor trip function are the main steamline radia- ability of the radiation monitoring systems, the NRC staff tion monitors on BWR main steam lines. De engineered recomrnends that channel functional tests on radiation safety features actuations are basically isolation functions monitorir'g equipment be performed quarteriy. For some and air cicanup functions. Many radiation instruments radiation monitonng equipment, this surveillance is perform a monitoring function; these instruments moni- already donc quarterly. Channel checks, source checks, tor for reactor coolant leakage, accident conditions in and calibrations would be done at their existing survet!-

containment, and the relcase of gaseous and liquid lance test intervals.

effluents.

As with other instrumentation, radiation monitors are The NRC staff also recommends that the vendor owners required to undergo three types of survetilances: a chan- groups study the reliability, set point drift, failure modes, nel check, a channel functional test and a calibration. In and alarm capabilities of radiation monitors (with industry addition, a source check is perfonned. panicipation) to determine if further decreases in testing and calibrations are possible.

NUREG-1366 34

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5 Instrumentati l

Findirg- dard may be excessive for one vendor's detectors, this l

o Radiation monitor testmg appears to require a large amount of resources. Secondly, the NRC depends on the accuracy of *.he licen- '

sees' reporting of releases of effluents from the site. In o Most failures of radiation monitors can be found order to have confidence in these releases, a reliable from channel checks, source checks or alarms. calibration standard is necessary.

o Dere is a large variation in the type and reliability of Individuallicensees may be abic to justify a program for ,

r:diation monitoring equipment among utilities. effluent mon toring instrumentation which does not in- '

c!ude this requirement but, on a generic basis, this re-Recommendations quirement appears to be necemry.

o in order to decrease licensee burden and increase ,.  !

the availability of radiation monitors, change the Find,mg monthly channel functional test to quanerly. NBS calibration standarus are necemry for effluent monitoring instrumentation because of the variety of in-  :

o The vendor owners groups should study whether struments used and the need for accurate measurements I further reductions in radiation monitor survedlance of effluent radioactivity.

testing are possible.

Recommendation )

l 5.15 Radioactive Gas Effluent Monitor Retin this reqm.rement. l Calibration Standard (PWR, 1 BWR) 5.16 Intermediate Range Monitor and BWRs and PWRs are required by theirTechmcal Specifi-cations to calibrate noble gas activity monitors at refuel- AveraEe Power Ranee Monitor ing. Some of these BWR Techmcal Speedications have Channel Functional Tests (BWR)-

the following note attached to this requirement.

IRM and APRM channel functional tests are performed The initial channel calibration shall be per- every 7 days, while all other RPS channel functional tests formed using one or more of the reference are performed once every 31 days.

radioactive standards certified by the National Bureau of Standards (NBS) or using standanis In the time available, the NRC staff could not determine that have been obtained from suppliers that the reason for this difference. De NRC staff should participate in measurement assurance activi- discuss this difference with the BWR Owners Group to ties with NBS. Dese standards shall permit determine whether there is a valid basis for this 6ffer-calibrating the system over its intended range ence. If justined, the surWance mterval for the IRM of energy and measurement range. For subse- and APRM channel functional tests should be changed to quent channel calibration, the initial reference every 31 days.

radioactive standards or radioactive sources that have been related to the initial cahbration shall be used- Findings

• IRM and APRM channel functional tests are per.

Ris requirement is viewed by some in the industry as fonned every 7 days whde all other RPS channel cxcessive since the equipment vendors supply informa.

functional tests are performed every 31 days.

tion or kits for calibrating monitors.The requirement for an NBS standard make: instrument calibration rnore ex-pensive. A search of plant Technica1 Specifications shows

• He reason for t his difference was not determin ed as th .t the NRC staff has not been rt. quiring an NBS stan- part of this effort because of time restraints.

dard for calibration consistently, but there appears to be a reasonable basis for the requirement. Recommendation First, there is a great vanability between radiation detec- De BWR Owners Group should determine if the 7-day tors at different sites and the calibmtion standards and requirement for channel functional tests on IRMs and procedures of these detectors.Rus, while an NBS stan. APRMs can be extended.

35 NUREG-1366

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9y kg UNITED STATES

'W* e NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666

• September 27, 1993

...e TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR POWER REACTORS l

SUBJECT:

LINE-ITEM TECHNICAL SPECIFICATIONS IMPROVEMENTS TO REDUCE j

l SURVEILLANCE REQUIREMENTS FOR TESTING DURING POWER OPERATION i

l (GENERIC LETTER 93-05) j

, 1 The staff of the U.S. Nuclear Regulatory Commission (NRC) has completed a com- j prehensive o: amination of surveillance requirements in technical specifications (TS) that require testing during power operation. This effort is a part of the NRC Technical Specifications Improvement Program (TSIP). The results of this work are reported in'NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements," December 1992. NUREG-1366 is available for l examination in the NRC Public Document Room, 2120 L Street, NW, Lower Level, {

w- Washington, D.C. .and for. purchase from the GPO Sales Program by wr,iling.,t.odhe,., ,,,,, , .. y' Superintendent of D'ocuments, U.S. Government Printing Office, P.O. Box 37082,':. "

Washington, DC 20013-708E. In performing this study, the staff found that',7 L.

while the majority of the testing at power is important, safety can.be' - N'"'

• improved, equipment degradatio'n decreased, and an unnecessary burden o'n

personnel resources eliminated by reducing the amount of testirg thit' the"TS require during power operation. However, only a small fraction of ~the TS surveillance intervals warranted relaxation. The staff has prepared thei N enclosed guidance to assist licensees in preparing a license amendment request to implement these recommendations as line-item TS improvements. The NRC

issued improved standard technical specifications in September 1992 that incorporated the recommendations of Nw EG-1366.

The staff encourages lice #nsees who plan to adopt these line-item TS improve-ments to propose TS changes that are consistent with the enclosed guidance.

Licensees may propose to implement any number of the TS changes that are . '

applicable to their facilities. NRC project managers will perform the review to ensure that the amendment requests conform to this guidance. Please cdntact 1 your project manager or the contact listed below if you have any questions on ,

this matter. -

Licensee action to propose TS changes under the guidance of this generic letter is voluntary. Therefore, such action is not a backfit under the provisions of Section 50.109 to Title 10 of the [. ode of Federal Reaulatto.pl (10 CFR 50.109).

The following information, although not requested under the provisions of 10 CFR 50.54(f), would help the NRC evaluate costs and benefits for licensees who propose the TS changes. described in this generic letter:

• licensee time and costs to prepare the amendment request a estimate of the long-term costs or savings accruing from this TS change 9309220159 -

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f Generic Letter 93-05 September 27, 1993 l

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Office of Management and Budget Cle'ar'ance Number 3150-0011, which expires June 30, 1994, covers this request. The estimated average number of burden hours is 40 person-hours per licensee response, including thosa needed to i assess the recommendations, search data sources, gather and analyze the data, and prepare the required letters. Send comments on this burden estinat,' or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (MNBB 7714), Division of Information Support Services, Office of Information i and Resource Management, U.S. Nuclear Regulatory Commission, Washingto'n, D.C., i 20555, and to Ronald Minsk, Office of Information and Regulatory Affairs (3150-0011), NE0B-3019, Office of Management and Budget, Washington, D.G,,,

20503.

Sincerely,

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James G. Partlow. .

Associats Director forLProjects'.. j

- Office of Nuclear Reac't'or Regulat. ion nomma - a > - s.o.' < . osmwoumem- -

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Enclosures:

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Guidance Improvements for

'to Implsmelit'i'nfline-Item Redu e'iTesting During Power Technical 0;ieratio6 . ~ , ' Specific'atidns

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List of Recently;Iss(uedfijRC Generic Letters

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Contact:

T. G. Dun'ning, NRR ' Y

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Enclosure 1 Generic Letter 93-05 GUIDANCE FOR IMPLEMENTING LINE-ITEM TECHNICAL SPECIFICATIONS IMPROVEMENTS 10 REDUCE TESTING DURING POWER OPERATION INTRODUCTION This enclosure provides guidance for preparing a license amendment request to change the technical specifications (TS) to reduce testing during power opera-tion. These line-item TS improvements are based on the recomendations of a U.S. Nuclear Regulatory Comission (NRC) study that included a comprehensive examination of surveillance requirements and is reported in NUREG-1366,

" Improvements to Technical Specifications Surveillance Requirements," ~

December 1992.

Each of the applicable recommendations in NUREG-1366 is addressed herein with examples of TS changes to the standard technical specifications (STS) requirements that were used as model TS when mant plants obtained their operating license. The title and number of each of these line-item improvements corresponds to the section title and number in NUREG-1366 in which the staff recommended the change. The staff is providing the NUREG recommendation for each item, but the NUREG finding.is provided only where it is necessary to' clarify the* intent of the NUREG recommendation...The. staff is e providing the wording for the changes to specific sections of the TS, using the f

noted model STS requirements with the reactor vendor identif.ied in brackets and-noted as "Typ" where it is' typical of the change that applies to the TS for p

reactors of more than one type or vendor. For a few of the recommendations, the staff is providing the wording that was used in an approved amendment request for a specific plant. In such cases, the plant is identified in brackets as the source of the guidance.

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i~ The proposed TS changes for plants that have TS in a format that is different than the STS should be consistent with the intent of the NUREG recommendation, the enclosed guidance,'and the format of individual plant TS.

COMPATIBILITY WITH OPERATING EXPERIENCE k Licensees should not propose changes to extend any surveillance interval if the recommendations of NUREG-1366 are not compatible with plant operating exper-ience. Therefore, each licensee should include a statement in the license' amendment request that all proposed TS changes are compatible with plant operating experience and are consistent with this guidance.

LINE-ITEM TS IMPROVEMENTS 4.1 Moderator Temperature Coefficient Measurements (PWR).

Findings: (1) Technical Specifications require a determination of moderator temperature. coefficient at 300 ppm boron concentration.

(2) If measured moderator temperature coefficient is more negative (less conservative than the TS value), the licensee must measure the moderator temperature coefficient every 14 EFPDs [ effective full-power days] until the end of the cycle. (3) Measuring the moderator temperature coefficient at low boron concentrations is difficult.

(4) VEPC0 [ Virginia Electric Power Company] proposed a method for

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.h Enclosure 1 Generic Letter 93-05  !

5.13 Turbine Oversoeed Protection System Testina (PWR. BWR)

Recommendation: Where the turbine manufacturer agrees, the turbine valve testing frequency should be changed to quarterly.

The following condition must be met and addressed to justify the use of this approach:

A statement is required confirming the turbine manufacturer's concurrence with the proposed change.

3/4.3.4 Turbine Overspeed Protection, [W STS (Typ)] TS 4.3.4.2: ..

~ The above required Turbine Overspeed Protection System shall be demonstrated OPERABLE:

a. At least once per 21 days by direct observation of the movement of each of the following valves through at least one complete cycle from the running position:

, (No change to the listing of turbine valves. Replaced "7" with "92" days and " cycling" with " direct observation of the movement"'of linh"valvet)'

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b. (Unused)

(Item b is noted as " Unused" since surveillance for direct' observation of .

valve movement is included in item a above.)

1 5.14 Radiation Monitors (PWR.'BWR) f Recommendation: ,In order to decrease li.censee burden and increase the' availability of radiation monitors, change the monthly channel functional test to quarterly.

i 3/4.3.2 Engineered Safety Feature' Actuation System Instrumentation,

[CE STS (Typ)]'TS Table 4.3-2: '

! Table 4.3-2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEMS INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL MODES FOR WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE CHECK TEST IS RE0VIRED FUNCTIONAL UNIT CALIBRATION

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5. SHIELD BUILDING FILTRATION (SBFAS) c e. Containment Radiation - High 1, 2, 3, 4 ,

. Gaseous Monitor 5 R D f<

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Generic Letter 93-05 (Table 4.3-2, cont.)

CHANNEL MODES FOR WHICH CHANNEL. CHANNEL FUNCTIONAL SURVEILLANCE CHECK CALIBRATION TEST' IS REQUIRED FUNCTIONAL UNIT (5.e, Cont.)

l Particulate 1, 2, 3, 4 Monitor S R Q R Q I, 2, 3, 4 l Area Monitor S I

7. CONTAINMEiT PURGE VALVES ISOLATION

e. Containment Radiation - High R Q I, 2, 3, 4 Gaseous Monitor S Particulate I; 2, 3, 4 Monitor S R Q l

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.Q - ^ ' 1; 2, 3, 4

' 'Areit$o[itor'.' R. .

- (Channel Functional Test frequency changed from "M" to "Q.") .

3/4 3.3 . Monitoring Instrumentation . Radiation Monitoring Instrumentation,

[CE STS (Typ)] TS Table 4.3-3:, .,

TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL, MODES FOR WHICH CHANNEL CHANNEL. . FUNCTIONAL SURVEILLANCE CHECK- 'CALIBRATILi! . TEST 'IS REOUIRED FliNCTIONAL UNIT e(No change) (No. change) .Q (No change)

(All items) i (Channel Functional Test frequency changed from "M" to "Q.")

J 3/4.3.3 Monitoring Instrumentation - Radioactive Liquid E'ffluent Monitoring Instivmentation, - Radioactive Gaseous Effluent Monitoring Instru-mentation, .[W STS (Typ)] TS Table 4.3-8 and Table 4.3-9:

No change in-ex'isting STS guidance is required. The surveillance interval for an Analog Channel Operational Test (equivalent of a Channel Functional Test for other reactor vendors) is specified as l "Q" (quarterly). Plants having a monthly test interval for this-surveillance may request a change in the test interval to quarterly.

5.15 Radioactive Gas Effluent Monitor Calibration Standard (PWR. BWR)

A TS change was not recommended for this item.  !

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