I TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JCY]VT CI'WJVERS GR 4CXrP A C77 VIT-Y · 2012-12-03 · I TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JCY]VT CI'WJVERS GR 4CXrP A C77 VIT-Y

I TECHNICAL SPECIFICATIONS TASK FORCETSTF A JCY]VT CI'WJVERS GR 4CXrP A C77 VIT-Y

August 6, 2010 TSTF-10-14PROJ0753

Attn: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, DC 20555-0001

SUBJECT: Submittal of TSTF-513, Revision 3 and TSTF-514, Revision 2

REFERENCES: 1. Letter from J. E. Dyer (NRC) to TSTF dated March 27, 2009.

2. RIS 2009-02, "Use of Containment Atmosphere Gaseous RadioactivityMonitors for Reactor Coolant System Leakage Detection Equipment atNuclear Power Reactors," January 29, 2009.

3. Letter from TSTF to NRC, "Change in Fee Exemption for TSTF-513 andTSTF-514, "dated June 21, 2010.

4. Memorandum to NRC Regional Administrators, Eric J. Leeds, Michael R.Johnson, Charles L. Miller, Michael F. Weber, Roy P. Zimmerman, fromCynthia A. Carpenter, "Enforcement Guidance Memorandum -Dispositioning Violations of NRC Requirements for Operability ofGaseous Monitors for Reactor Coolant System Leakage Detection,"January 30, 2009.

The Notices for Comment for TSTF-513, "Revise PWR Operability Requirements and Actionsfor RCS Leakage Instrumentation," and TSTF-514, "Revise BWR Operability Requirements andActions for RCS Leakage Instrumentation," were published in the Federal Register on October 9,2009 and April 13, 2010, respectively. The TSTF had requested and been granted a feeexemption for NRC review of the TSTF Travelers (Reference 1). The fee waiver request andapproval were based on supporting the resolution of containment atmosphere gaseousradioactivity monitor operability concerns described in Reference 2.

On June 11, thle NRC informed the TSTF that one proposed change in TSTF-513 and TSTF-514should not have been included in the fee exemption. TSTF-513 and TSTF-514 proposed torevise the actions taken when there are no operable Reactor Coolant System (RCS) leakagedetection instruments. The TSTF included this change in order to address "inoperablecontainment atmosphere gaseous radioactivity monitoring systems in an integrated fashion," asstated in Reference 2. However, the NRC has concluded these changes are not necessary.

In Reference 3, the TSTF stated that the industry agrees that the proposed changes to address nooperable RCS leakage detection instruments should not fall under the fee waiver and stated that

11921 Rockville Pike, Suite 100, Rockville, MD 20852 PWROG--Th r J-Phone: 301-984-4400, Fax: 301-984-7600 ,'4 OWNERS' GROUPAdministration by EXCEL Services Corporation 0WVner;, -bj

TSTF 10-14August 6, 2010

Page 2

the industry would pay review fees for the review associated with those changes. At the July 15,2010 public meeting between the TSTF and the NRC, the NRC did not accept the TSTF'sproposed resolution and requested that the TSTF revise TSTF-513 and TSTF-514 to not includethe proposed changes to address the condition of no operable RCS leakage detection instruments.

Attached for NRC review is TSTF-513, Revision 3, and TSTF-514, Revision 2. The review ofTSTF-513 and TSTF-514 was granted a waiver of NRC review fees in Reference 1.

Issuance of the Notices of Availability for TSTF-513. and TSTF-514 is a milestone in the NRC'sEnforcement Guidance Memorandum (EGM) regarding the containment atmosphere gaseousradioactivity monitoring system (Reference 4). In order to ensure there are no

misunderstandings which would prevent rapid adoption of the Travelers by licensees asanticipated by the EGM, we request the opportunity to review the Notices prior to publication.

Should you have any questions, please do not hesitate to contact us.

)&-I4Mt JAKt4Kenneth J. Schrader (PWROG/W)

Thomas W. Raidy (PWROG/CE)

Donald W. Gregoire WROG)

Reen 'Gambrell (PWROG/B&W)

cc: Frederick Brown, Director, Division of Inspection and Regional SupportRobert Elliott, Technical Specifications Branch, NRCBarry Miller, Licensing Processes Branch, NRC

WOG-196, Rev. 0 TSTF-513, Rev. 3

Technical Specification Task ForceImproved Standard Technical Specifications Change Traveler

Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation

NUREGs Affected: [ 1430 [ 1431 V 1432 rD 1433 D] 1434

Classification 1) Technical Change Recommended for CLIIP?: Yes

Correction or Improvement: Improvement NRC Fee Status: Exempt

Benefit: Avoids Future Amendments

See attached.

Revision History

OG Revision 0 Revision Status: Closed

Revision Proposed by: PWROG

Revision Description:Original Issue

Owners Group Review InformationDate Originated by OG: 13-Oct-08

Owners Group Comments(No Comments)

Owners Group Resolution: Approved Date: 31-Oct-08

TSTF Review Information

TSTF Received Date: 07-Nov-08 Date Distributed for Review 07-Nov-08

OG Review Completed: k BWOG [] WOG [. CEOG F/ BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 14-Nov-08

NRC Review Information

NRC Received Date: 14-Nov-08

NRC Comments:

1/8/09 - The NRC requested that the TSTF revise TSTF-51 3 to clarify the Bases description of theOperability requirements. In addition, a Condition Note was added to new Condition D to clarify theapplicability of the Condition.

Final Resolution: NRC Requests Changes: TSTF Will Revise Final Resolution Date: 08-Jan-09

TSTF Revision 1 Revision Status: Closed

05-Aug-JOTraveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.



Revision Proposed by: NRC

Revision Description:TSTF-513 was revised to address NRC comments and to clarify the application of the specifications.* Clarified the Bases description of the Operability requirements.* A Condition Note was added to new Condition D (NUREG-1431 & -1432, Condition C in NUREG-1430)

to clarify the applicability of the Condition.* Incorrect usage of the word "required" was eliminated.* Consistent use of brackets for plant-specific designs was applied.

Owners Group Review InformationDate Originated by OG: 14-Jan-09


Owners Group Resolution: Approved Date: 28-Jan-09


TSTF Received Date: 14-Jan-09 Date Distributed for Review 06-Feb-09

OG Review Completed: [ BWOG F. WOG 7] CEOG [ BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 28-Feb-09

NRC Review InformationNRC Received Date: 18-Feb-09

NRC Comments:

Fee exemption granted on 3/30/09.

NRC provided an RAI on 5/6/09. TSTF-513 was revised to address the RAI questions.

Final Resolution: Superceded by Revision



Revision Description:TSTF-513 is revised in response to the NRC's May 6, 2009 RAI.

The Background Bases are revised to state that the RCS leakage detection monitor setpoints are typically setto be as sensitive as practicable while minimizing spurious alarms. The statement is bracketed as not all plantshave alarmed RCS leakage instrumentation.

The LCO Bases of the containment sump are revised to provide additional provisions to describe plant-specific designs.

05-Aug-10Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.

WOG-196, Rev. 0R TSTF-513, Rev. 3


Owners Group Review InformationDate Originated by OG: 30-May-09


Owners Group Resolution: Approved Date: 18-Jun-09


TSTF Received Date: 30-May-09 Date Distributed for Review 30-May-09

OG Review Completed: V BWOG [] WOG [] CEOG V BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 18-Jun-09


NRC Received Date: 26-Jun-09

NRC Comments:

The NRC issued the Notice for Comment on 10/9/2009.

The NRC requested that the TSTF revise the Traveler to remove the change associated with no operable RCSleakage monitoring instrumentation, as that change was not seen as being directly related to the issuedescribed in Regulatory Issue Summary 2009-02, Rev. l,."Use of Containment Atmosphere GaseousRadioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear PowerReactors," which was the basis for the TSTF's fee waiver request. In a letter dated June 21, 2010, the TSTFvolunteered to pay for the NRC review of the change associated with no Operable RCS leakage monitoringinstrumentation. At the July 15, 2010 TSTF/NRC public meeting, the NRC did not accept the TSTF's offerand requested that the TSTF revise the Traveler to remove the changes. The TSTF agreed to revise theTraveler as requested.


TSTF Revision 3 Revision Status: Active


Revision Description:The NRC requested that the TSTF revise the Traveler to remove the change associated with no operable RCSleakage monitoring instrumentation, as that change was not seen as being directly related to the issuedescribed in Regulatory Issue Summary 2009-02, Rev. 1, "Use of Containment Atmosphere GaseousRadioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors,"which was the basis for the TSTF's fee waiver request. In a letter dated June 21, 2010, the TSTF volunteeredto pay for the NRC review of the change associated with no Operable RCS leakage monitoringinstrumentation. At the July 15, 2010 TSTF/NRC public meeting, the NRC did not accept the TSTF's offerand requested that the TSTF revise the Traveler to remove the changes. The TSTF agreed to revise theTraveler as requested.

05-Aug-lOTraveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.

WOG-196, Rev. 0 TSTF-513, Rev. 3WOG-196, Rev. 0 TSTF-513, Rev. 3


The revision removes the changes to Condition F (Condition D in NUREG-1430) and the associated change tomove Condition E to Condition G (Condition C to Condition E for NUREG-1430). The associated changes tothe Bases are removed, as well as the discussion of the removed changes from the justification.

Owners Group Review InformationDate Originated by OG: 23-Jul-10


Owners Group Resolution: Approved Date: 04-Aug-10


TSTF Received Date: 23-Jul-10 Date Distributed for Review 23-Jul-10

OG RevieW Completed: V BWOG V WOG [] CEOG W BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 04-Aug-10


NRC Received Date: 06-Aug-10

Affected Technical SpecificationsBkgnd 3.4.13 Bases RCS Leakage Detection Instrumentation

LCO 3.4.13 Bases RCS Leakage Detection Instrumentation

Action 3.4.13.C RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only

Change Description: New Condition

Action 3.4.13.C Bases RCS Leakage Detection Instrumentation . NUREG(s)- 1430 Only


Action 3.4.13.D RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only

Change Description: Renamed D

Action 3.4.13.D Bases RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only

Change Description: Renamed D

Action 3.4.13.D RCS Leakage Detection Instrumentation NUREG(s)' 1431 1432 Only


05-Aug-JO

Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.


Action 3.4.13.D RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only

Change Description: Relabeled E

Action 3.4.13.D Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only


Action 3.4.13.D Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only


Action 3.4.13.E RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only

Change Description: Relabeled F

Action 3.4.13.E Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only


Action 3.4.13.F RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only

Change Description: Relabeled G

Action 3.4.13.F Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 1432 Only



TSTF-513, Rev. 3

1.0 Description

Specification 3.4.15, "RCS Leakage Detection Instrumentation," requires instrumentationto detect significant reactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to a gross failure. TheImproved Standard Technical Specifications (ISTS) require one containment sumpmonitor (for Westinghouse plants, level or discharge flow), one containment atmosphereradioactivity monitor (gaseous or particulate), and (optionally for Westinghouse andCombustion Engineering plants) one containment air cooler condensate flow rate monitor.

Questions have been raised regarding the Operability requirements for these instruments.In particular, improvements in plant fuel integrity have resulted in a reduction of theReactor Coolant System (RCS) activity. As a result, the containment atmosphereradioactivity monitors may not be capable of promptly detecting an increase in RCSleakage.

The proposed change revises the Bases to clearly define the RCS leakage detectioninstrumentation Operability requirements and to modify the Actions to be taken when thecontainment atmosphere gaseous radioactivity monitor is the only Operable monitor torequire additional, more frequent monitoring of other indications of RCS leakage and toshorten the time allowed to restore another monitor to Operable status.

2.0 Proposed Chang!e

Specification 3.4.15, "RCS Leakage Detection Instrumentation," is revised to add a newCondition. New Condition D (Condition C in NUREG-1 430) is applicable when thecontainment atmosphere gaseous radioactivity monitor is the only Operable monitor (i.e.,all other monitors are inoperable). The Required Actions require analyzing grab samplesof the containment atmosphere every 12 hours and restoring another monitor within 7days. The subsequent Conditions are renumbered to reflect in addition of the newCondition.

The Bases are revised to clearly define the RCS leakage detection instrumentationOperability requirements in the LCO Bases and to eliminate discussion from the Basesthat could be erroneously construed as Operability requirements. The Bases are alsorevised to reflect the changes to the Technical Specifications and to more accuratelyreflect the existing Technical Specifications.

Three corrections are made:

In several locations in all three NUREGs, the specifications incorrectly refer to a"required" containment sump monitor or "required" containment air cooler flow ratemonitor when the LCO does not provide for more than one monitor. The term"required" is reserved for situations in which there are multiple ways to meet the LCO,such as the requirement for either a gaseous or particulate radiation monitor. Theincorrect use of the term "required" is removed.

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TSTF-513, Rev. 3

* The Note, "Not required until 12 hours after establishment of steady state operation,"is currently incorrectly placed on Required Action C.1 (Perform SR 3.4.15.1, ChannelCheck) instead of Required Action C.2 (Perform SR 3.4.13.1, RCS mass balance) asin the other ISTS NUREGs. The Note is moved to Required Action C.2. The Basescorrectly state that the Note applies to performance of SR 3.4.13.1.

* In NUREG-1431 and NUREG-1432, the containment air cooler condensate flow ratemonitor is plant-specific, and therefore bracketed in the NUREG. The specificationsand Bases are revised to consistently bracket references to this monitor.

3.0 Background

General Design Criterion (GDC) 30 of Appendix A to 10 CFR 50 requires means fordetecting and, to the extent practical, identifying the location of the source of RCSLeakage. Regulatory Guide (RG) 1.45, Revision 0, "Reactor Coolant Pressure BoundaryLeakage Detection Systems," May 1973, describes acceptable methods for selectingleakage detection systems. Revision I of RG 1.45 was issued in May 2008. However,operating nuclear power plants are not committed to Revision I of RG 1.45.

NRC Information Notice (IN) 2005-24, "Non-conservatism in Leakage DetectionSensitivity," (ADAMS Accession No. ML051780073) pointed out that the reactorcoolant activity assumptions used for designing the containment radiation gaseousradiation monitor may be greater than the RCS radioactivity level present during normaloperation. As a result, the containment gas channel may not be able to detect a I gpmleak within 1 hour at the current RCS radioactivity level.

RG 1.45, Rev. 0, Regulatory Position C.2 states that "Leakage to the primary reactorcontainment from unidentified sources should be collected and the flow rate monitoredwith an accuracy of one gallon per minute (gpm) or better." Regulatory Position C.3states, "At least three separate detection methods should be employed and two of thesemethods should be (1) sump level and flow monitoring and (2) airborne particulateradioactivity monitoring. The third method may be selected from the following: a.monitoring of condensate flow rate from air coolers, b. monitoring of airborne gaseousradioactivity. Humidity, temperature, or pressure monitoring of the containmentatmosphere should be considered as alarms or indirect indication of leakage to thecontainment." Regulatory Position C.5 states, "The sensitivity and response time of eachleakage detection system in regulatory position [C.]3. above employed for unidentifiedleakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in lessthan one hour." RG 1.45, Rev. 0, states, "In analyzing the sensitivity of leak detectionsystems using airborne particulate or gaseous radioactivity, a realistic primary coolantradioactivity concentration assumption should be used. The expected values used in theplant environmental report would be acceptable." Many plants pre-date the issuance ofRG 1.45 and their plant-specific licensing basis is described in their UFSAR. In eithercase, the appropriate sensitivity of the atmospheric radiation monitors is dependent on thedesign assumptions and the plant licensing basis of each licensee.

0

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TSTF-513, Rev. 3

The ISTS Specification 3.4.15 Bases do not clearly define the basis for Operability forthe RCS Leakage Instrumentation. Operability requirements should be defined in theLCO section ofthe Bases. However, the current Bases contain information that could beconstrued as Operability requirements in the Background, Applicable Safety Analysis,and LCO sections. In addition, the current Bases do not accurately describe theOperability of a detector as being based on the design assumptions and licensing basis forthe plant.

Because the containment atmosphere gaseous radiation monitor cannot always detect anRCS leak at a rate of I gpm within 1 hour, some plants have removed the monitor fromthe Technical Specification list of required monitors. However, experience has shownthat the containment atmosphere gaseous radiation monitor is useful to detect an increasein RCS leak rate and provides a diverse means to confirm an RCS leak exists when othermonitors detect an increase in RCS leak rate. Therefore, the preferred solution is to retainthe containment atmosphere gaseous radiation monitor in the LCO 3.4.15 list of requiredequipment, and to revise the Actions to require additional monitoring and to provide lesstime before a plant shutdown is required when the containment atmosphere gaseousradiation monitor is the only Operable monitor.

4.0 Technical Analysis

This change will reduce the number of unnecessary MODE changes and requests forenforcement discretion by clarifying the Operability requirements for the RCS leakagedetection instrumentation and by allowing a limited time to repair one or more of theinoperable monitors. A plant shut down solely as a result of the loss of the preferred TSmonitoring capability could be avoided. The use of alternate leakage detectionmonitoring for a limited time is an appropriate response to this condition.

The proposed Bases changes will clarify the Operability requirements of the RCS leakagedetection instrumentation. Phrases that are not consistent with RG 1.45, Rev. 0, such as"a high degree of confidence" and "extremely small leaks" are eliminated or replaced -with terminology that accurately describes the design assumptions of the system. Allreference to RG 1.45 are revised to reference Revision 0 of the RG. Information in theBackground and Applicable Safety Analysis sections of the Bases that could be construedas Operability requirements is deleted. The LCO section of the Bases is expanded toprovide a detailed discussion of the Operability requirements for each of the requiredinstruments. For the containment atmosphere radioactivity monitors, the Bases clearlyrelate Operability to the design assumptions and licensing basis for the plant and areference to the Final Safety Analysis Report description of the design basis of themonitors is included.

As described in 10 CFR 50.36(c)(2)(i), the Limiting Condition for Operation andassociated Operability requirements represent the lowest functional capability orperformance levels of equipment required for safe operation of the facility. In practice,the leakage monitoring instrumentation is typically set to provide the most sensitiveresponse without distracting the reactor operators with unnecessary alarms.

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TSTF-513, Rev. 3

When the containment atmosphere gaseous radiation monitor is the only Operablemonitor, the current Technical Specifications require performance of SR 3.4.13.1 (massbalance) once per 24 hours and restoration of the inoperable sump monitor within 30 days.The proposed change requires analyzing grab samples from the containment atmosphereand restoration of at least one additional monitor within 7 days. The RCS mass balanceis sensitive enough to detect a one gpm leak rate in one hour and is the primary methodused to verify compliance with the RCS leakage limits. However, an RCS mass balancecalculation requires a relatively lengthy period of steady state operation to provideaccurate results. The ability to perform grab sampling during periods of power change isdesirable and provides an additional compensatory method to the currently required RCSmass balance. A containment grab sample is comparable to the containment particulateradiation monitor with respect to the ability to detect RCS leakage. Due to the time totake and analyze the grab sample, this is not a continuous monitoring method. However,by reducing the time between grab samples there will be no significant loss of monitoringcapability during the limited time period allowed by the proposed change. The 12 hour(once per shift) performance of cont~ainment grab samples is reasonable given theavailability of the containment atmosphere gaseous radiation monitor. The 7 dayCompletion Time to restore another monitor is reasonable given the diverse methodsavailable to detect an RCS leak and the low probability of a large RCS leak during thisperiod.

Most licensees have been licensed for Leak-Before-Break (LBB). The basic concept ofleak-before-break (LBB) is that certain piping material has sufficient fracture toughness(i.e., ductility) to resist rapid flaw propagation. A postulated flaw in such piping wouldnot lead to pipe rupture and potential damage to adjacent safety related systems,structures and components before the plant could be placed in a safe, shutdown condition.Before pipe rupture, the postulated flaw would lead to limited but detectable leakagewhich would be identified by the leak detection systems in time for the operator to takeaction. The NRC staff reviews the application of LBB methodology to primary systempiping to ensure that certain safety margins are satisfied to assure the structural integrityof the pipe. There is significant conservatism in this evaluation. SRP Section 3.6.3specifies a margin of the square-root of 2 be applied to the loads to assure that leakage-size flaws are stable at the normal load plus safe-shutdown earthquake load. A margin of10 is to be applied to leakage so that detection of leakage from the postulated flaw size isensured when the pipe is subjected to normal operational loads. In addition, the criticalflaw size should be twice as large as the leakage flaw size (i.e., a margin of 2 on leakageflaw size). The proposed actions for inoperable RCS leakage detection instrumentationmaintain sufficient continuity and diversity of RCS leakage detection capability that anextremely low probability of undetected RCS leakage leading to pipe rupture ismaintained.

5.0 Regulatory Analysis

5.1 No Significant Hazards Consideration

The Technical Specification Task Force (TSTF) has evaluated whether or not asignificant hazards consideration is involved with the proposed generic change by

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TSTF-513, Rev. 3

focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," asdiscussed below:

1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable RCS leakageinstrumentation. monitor is the containment atmosphere gaseous radiation monitor.The monitoring of RCS leakage is not a precursor to any accident previouslyevaluated. The monitoring of RCS leakage is not used to mitigate theconsequences of any accident previously evaluated.

Therefore, it is concluded that this change does not involve a significant increasein the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of

accident from any accident previously evaluated?

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable RCS leakageinstrumentation monitor is the containment atmosphere gaseous radiation monitor.The proposed change does not involve a physical alteration of the plant (no newor different type of equipment will be installed) or a change in the methodsgoverning normal plant operation.

Therefore, it is concluded that this change does not create the possibility of a newor different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable RCS leakageinstrumentation monitor is the containment atmosphere gaseous radiation monitor.Reducing the amount of time the plant is allowed to operate with only thecontainment atmosphere gaseous radiation monitor Operable increases the marginof safety by increasing the likelihood that an increase in RCS leakage will bedetected before it potentially results in gross failure.

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TSTF-513, Rev. 3

Therefore, it is concluded that this change does not involve a significant reductionin a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significanthazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly,a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria

10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion30, "Quality of reactor coolant pressure boundary," requires that means be provided fordetecting and, to the extent practical, identifying the location of the source of reactorcoolant leakage. The specific attributes of the reactor coolant leakage detection systemsare outlined in Regulatory Positions I through 9 of Regulatory Guide 1.45, Rev. 0.

10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 4,"Environmental and Dynamic Effects Design Bases," requires components to be designedto accommodate dynamic effects associated with postulated pipe ruptures. However,these dynamic effects may be excluded if the Commission approves analysesdemonstrating that the probability of fluid system piping rupture is extremely low underconditions consistent with the design basis for the piping. Most licensees have beenlicensed for Leak-Before-Break (LBB). The NRC staff reviews the application of LBBmethodology to primary system piping to ensure that certain safety margins are satisfiedto assure the structural integrity of the pipe. The proposed actions for inoperable RCSleakage detection instrumentation maintain sufficient continuity and diversity of RCSleakage detection capability that an extremely low probability of undetected RCS leakageleading to pipe rupture is maintained.

10 CFR 50.36, "Technical Specifications," paragraph (c)(2)(ii)(A), specifies that aLimiting Condition for Operation be established for installed instrumentation that is usedto detect and indicate in the control room a significant abnormal degradation of thereactor coolant pressure boundary. This instrumentation is required by Specification3.4.15, "RCS Leakage Detection Instrumentation." The modification of the Actions inSpecification 3.4.15 is not in conflict with the 10 CFR 50.36 requirements. The proposedchanges do not adversely impact the ability of the Reactor Coolant System leakagedetection system to function as designed and do not impact conformance to the applicableGDCs. Therefore, the proposed changes are consistent with all applicable regulatoryrequirements or criteria.

Based on the considerations discussed above, (1) there is reasonable assurance that thehealth and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission'sregulations, and (3) the approval of the proposed change will not be inimical to thecommon defense and security or to the health and safety of the public.

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TSTF-513, Rev. 3

6.0 Environmental Consideration

A review has determined that the proposed change would change a requirement withrespect to installation or use of a facility component located within the restricted area, asdefined in 10 CFR 20, or would change an inspection or surveillance requirement.However, the proposed change does not involve (i) a significant hazards consideration, (ii)a significant change in the types or significant increase in the amounts of any effluent thatmay be released offsite, or (iii) a significant increase in individual or cumulativeoccupational radiation exposure. Accordingly, the proposed change meets the eligibilitycriterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to10 CFR 51.22(b), no environmental impact statement or environmental assessment needbe prepared in connection with the proposed change.

7.0 References

None.

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TSTF-513, Rev. 3

RCS Leakage Detection Instrumentation3.4.15

3.4 REACTOR COOLANT SYSTEM (RCS)

3.4.15 RCS Leakage Detection Instrumentation

L8O 3.4.15 The following RCS leakage detection instrumentation shall beOPERABLE:

a. One containment sump monitor and

b. One containment atmosphere radioactivity monitor (gaseous orparticulate).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. ReqiFe4-!C.eontainment A.1 --------- NOTE --------------sump monitor Not required until 12 hoursinoperable, after establishment of

steady state operation.

Perform SR 3.4.13.1. Once per 24 hours

AND

A.2 Restore Fequired 30 dayscontainment sump monitorto OPERABLE status.

B. Required containment B.1.1 Analyze grab samples of Once per 24 hoursatmosphere radioactivity the containmentmonitor inoperable, atmosphere.

OR

BWOG STS 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


ACTIONS (continued)


B.1.2 --------- NOTE-------Not required until 12 hoursafter establishment ofsteady state operation.


AND

B.2 Restore required 30 dayscontainment atmosphereradioactivity monitor toOPERABLE status.

-NOTE -------------- C. 1 Analyze .rab samples of Once-per 12 hotirsOnly applicable when the the containmentcontainment atmosphere atmosphere.gaseous radiation monitor isthe only OPERABLE ANDmonitor.

C.2 Restore containment sump 7 daysmonitor to OPERABLE

C Containment sump status.monitor inoperable.

DG. Required Action and DG.1 Be in MODE 3. 6 hoursassociated CompletionTime not met. AND

DG.2 Be in MODE 5. 36 hours

ED.Both required monitors ED.1 Enter LCO 3.0.3. Immediatelyinoperable.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

.BWOG STS 3.4.15,-2 Rev. 3.0, 03/31/04

I

TSTF-513, Rev. 3

RCS Leakage Detection InstrumentationB 3.4.15,

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation

BASES

BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for,detecting and, to the extent practical, identifying the location of the sourceof RCS LEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2) describesacceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significantreactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to agross failure. Thus, an early indication or warning signal is necessary topermit proper evaluation of all unidentified LEAKAGE. [In addition tomeeting the OPERABILITY requirements, the monitors are typically set toprovide the most sensitive response without causing an excessivenumber of spurious alarms.1

Industr; prac-ti-e- has;R rshownA tha-t ;wFaterF flow changes Of 0.5 to 1.0 gpmcan readily bep dePtpecte-d in contained volumes by monitoring ch~anges inwatefr level, in flow rate, or in the operating frequency of a pump. Thecontainment sump used to collect unidentified LEAKAGE is instrumentedto alarm for increases above of 0.5 to 1.0 gpm in the normal flow rates.This sensitivity is acptable for de-tting icrea i

I FAKAGEF

The reactor coolant contains radioactivity that, when released to thecontainment, may eao-be detected by radiation monitoringinstrumentation. Reactor coolant radioactivity levels will be low du'rng

initial ratrstartup and for;-a fewq weeks therea;fter until actiatecorrsio prducts have been for-med- an;d fission products appear from

fuel' eAlmnt c•ladding contamn•,-,;ation÷ Or cladding defects. Instrumentsensitiviti of i0-•, ,pii radioactivity for pa.ticulate monitaFiRg and oa4 -6'PWG pF/cadioactivity for gaseous monitoring are practical fopr theseleakage detection systems. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE.

Other indications may be used to detect an increase in unidentifiedLEAKAGE; however, they are not required to be OPERABLE by thisLCO. An increase in humidity of the containment atmosphere wouldindicate release of water vapor to the containment. Dew pointtemperature measurements can thus be used to monitor humidity levelsof the containment atmosphere as an indicator of potential RCSLEAKAGE. A .oF incre.e.i dew point is. well within the sensiti rangeof availa:ble instru-ments.

BWOG STS B 3.4.15-1 Rev. 3.0, 03/31/04BWOG STS B 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3

RCS Leakage Detection InstrumentationB 3.4.15

BASES

BACKGROUND (continued)

Since the humidity level is influenced by several factors, a quantitativeevaluation of an indicated leakage rate by this means may bequestionable and should be compared to observed increases in liquid.flow into or from the containment sump [and condensate flow from aircoolers]. Humidity level monitoring is considered most useful as anindirect alarm or indication to alert the operator to a potential problem.Humidity monitors are not required for this LCO.

Air temperature and pressure monitoring methods may also be used toinfer unidentified LEAKAGE to the containment. Containmenttemperature and pressure fluctuate slightly during plant operation, but arise above the normally indicated range of values may indicate RCSLEAKAGE into the containment. The relevance of temperature andpressure measurements are-isaffected by containment free volume and,for temperature, detector location. Alarm signals from these instrumentscan be valuable in recognizing rapid and sizable leakage to thecontainment. Temperature and pressure monitors are not required bythis LCO.

The above-mentioned LEAKAGE detection methods or systems differ insensitivity and response time. [Some of these systems could serve asearly alarm systems signaling the operators that closer examination ofother detection systems is necessary to determine the extent of anycorrective action that may be required.1

APPLICABLE The need to evaluate the severity of an alarm or an indication is importantSAFETY to the operators, and the ability to compare and verify with indicationsANALYSES from other systems is necessary. The system respon. e times and

enitiVities are described in the FSAR (Ref. 3). Multiple insrumenlocations are utilized, if eeded, to ensure the transport delay time of the

oVerall response time.

The safety significance of RCS LEAKAGE varies widely depending on itssource, rate, and duration. Therefore, detecting and monitoring reactorcoolant LEAKAGE into the containment area are necessary. Quicklyseparating the identified LEAKAGE from the unidentified LEAKAGEprovides quantitative information to the operators, allowing them to takecorrective action should a leak occur detrimental to the safety of the unitand the public.

RCS leakage detection instrumentation satisfies Criterion 1 of10 CFR 50.36(c)(2)(ii).

BWOG STS .B 3.4.15-2 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES

LCO One method of protecting against large RCS LEAKAGE derive, f,,,,m theability Of instF...ent6 to rapidly detect eAtremely small leaks. This LCOrequires instruments of diverse monitoring principles to be OPERABLE toprovide aconfidence that small amounts of unidentifiedLEAKAGE extremely small leaks are detected in time to allow actions toplace the plant in a safe condition when RCS LEAKAGE indicatespossible RCPB degradation.

The LCO requires two instruments to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE. [Thecontainment sump consists of the normal sump and the emergencysump. The LCO requirements apply to the total amount of unidentifiedLEAKAGE collected in [thellbothl sumpfsl.l The monitor on thecontainment sump detects [level or flow rate or the operating frequency ofa pump] and is instrumented to detect when there is [leakage ofi [anincrease above the normal value byl 1 gpm. The identification of [anincrease in] unidentified LEAKAGE will be delayed by the time requiredfor the unidentified LEAKAGE to travel to the containment sump and itmay take longer than one hour to detect a 1 qpm increase in unidentifiedLEAKAGE, depending on the origin and maqnitude of the LEAKAGE.This sensitivity is acceptable for containment sump monitorOPERABILITY.

The reactor coolant contains radioactivity that, when released to thecontainment, can be detected by the gaseous or particulate containmentatmosphere radioactivity monitor. Only one of the two detectors isrequired to be OPERABLE. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE, but have recognizedlimitations. Reactor coolant radioactivity levels will be low during initialreactor startup and for a few weeks thereafter, until activated corrosionproducts have been formed and fission products appear from fuelelement cladding contamination or cladding defects. If there are few fuelelement cladding defects and low levels of activation products, it may notbe possible for the gaseous or particulate containment atmosphereradioactivity monitors to detect a 1 qpm increase within 1 hour duringnormal operation. However, the gaseous or particulate containmentatmosphere radioactivity monitor is OPERABLE when it is capable ofdetecting a 1 gpm increase in unidentified LEAKAGE within 1 hour givenan RCS activity equivalent to that assumed in the design calculations forthe monitors (Reference 3).

The LCO requirements are satisfied when monitors of diversemeasurement means are available. Thus, the containment sump monitor,in combination with a particulate or gaseous radioactivity monitor,provides an acceptable minimum.

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APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3,and 4, RCS leakage detection instrumentation is required to beOPERABLE.

In MODE 5 or 6, the temperature is < 200°F and pressure is maintainedlow or at atmospheric pressure. Since the temperatures and pressuresare far lower than those for MODES 1, 2, 3, and 4, the likelihood ofleakage and crack propagation is much smaller. Therefore, therequirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2

With the requiiFed-containment sump monitor inoperable, no other form ofsampling can provide the equivalent information.

However, the containment atmosphere activity monitor will provideindications of changes in leakage. Together with the containmentatmosphere radioactivity monitor, the periodic surveillance for RCSinventory balance, SR 3.4.13.1, water inventory balance, must beperformed at an increased frequency of 24 hours to provide informationthat is adequate to detect leakage. A Note is added allowing thatSR 3.4.13.1 is not required to be performed until 12 hours afterestablishing steady state operation (stable temperature, power level,pressurizer and makeup tank levels, makeup and letdown, and [RCP sealinjection and return flows]). The.12 hour allowance provides sufficienttime to collect and process all necessary~data after stable plant conditionsare established.

Restoration of the FequiFed sump monitor to OPERABLE status isrequired to regain the function in a Completion Time of 30 days after themonitor's failure. This time is acceptable considering the frequency andadequacy of the RCS water inventory balance required by RequiredAction A. 1.

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BASES

ACTIONS (continued)

B.1.1, B.1.2, and B.2

With required gaseous or particulate containment atmosphereradioactivity monitoring instrumentation channels inoperable, alternativeaction is required. Either grab samples of the containment atmospheremust be taken and analyzed or water inventory balances, in accordancewith SR 3.4.13.1, must be performed to provide alternate periodicinformation. With a sample obtained and analyzed or a water inventorybalance performed every 24 hours, the reactor may be operated for up to30 days to allow restoration of at least one of the radioactivity monitors.

The 24 hour interval provides periodic information that is adequate todetect leakage. A Note is added allowing that SR 3.4.13.1 is not requiredto be performed until 12 hours after establishing steady state operation(stable temperature, power level, pressurizer and makeup tank levels,makeup and letdown, and [RCP seal injection and return flows]). The12 hour allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established. The 30 dayCompletion Time recognizes at least one other form of leak detection isavailable.

C.1 and C.2

With the containment sump monitor inoperable, the only means ofdetecting LEAKAGE is the required containment atmosphere radiationmonitor. A Note clarifies that this Condition is applicable when the onlyOPERABLE monitor is the containment atmosphere gaseous radiationmonitor. In addition, this configuration does not provide the requireddiverse means of leakage detection. Indirect methods of monitoring RCSleakage must be implemented. Grab samples of the containmentatmosphere must be taken and analyzed to provide alternate periodicinformation. The 12 hour interval is sufficient to detect increasing RCSleakage. The Required Action provides 7 days to restore another RCSleakage monitor to OPERABLE status to regain the intended leakagedetection diversity. The 7 day Completion Time ensures that the plant willnot be operated in a degraded configuration for a lengthy time period.

DG.1 and DG.2

If a Required Action of Condition A, er-B, or C cannot be met within therequired Completion Time, the unit must be brought to a MODE in whichthe LCO does not apply. To achieve this status, the unit must be broughtto at least MODE 3 within 6 hours and to MODE 5 within 36 hours. Theallowed Completion Times are reasonable, based on operating

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experience, to reach the required plant conditions from full powerconditions in an orderly manner and without challenging plant systems.

ED. 1

With both required monitors inoperable, no automatic means ofmonitoring leakage are available, and immediate plant shutdown inaccordance with LCO 3.0.3 is required.

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TSTF-513, Rev. 3


BASES

SURVEILLANCE SR 3.4.15.1REQUIREMENTS

SR 3.4.15.1 requires the performance of a CHANNEL CHECK of therequired containment atmosphere radioactivity monitor. The check givesreasonable confidence that each channel is operating properly. TheFrequency of 12 hours is based on instrument reliability and is reasonablefor detecting off normal conditions.

SR 3.4.15.2

SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONALTEST of the required containment atmosphere radioactivity monitor. Asuccessful test of the required contact(s) of a channel relay may beperformed by the verification of the change of state of a single contact ofthe relay. This clarifies what is an acceptable CHANNEL FUNCTIONALTEST of a relay. This is acceptable because all of the other requiredcontacts of the relay are verified by other Technical Specifications andnon-Technical Specifications tests at least once per refueling interval withapplicable extensions. The test ensures that the monitor can perform itsfunction in the desired manner. The test verifies the alarm setpoint andrelative accuracy of the instrument string. The Frequency of 92 daysconsiders instrument reliability, and operating experience has shown itproper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4

These SRs require the performance of a CHANNEL CALIBRATION foreach of the required RCS leakage detection instrumentation channels.The calibration verifies the accuracy of the instrument string, including theinstruments located inside containment. The Frequency of [18] months isa typical refueling cycle and considers channel reliability. Again,operating experience has proven this Frequency is acceptable.

REFERENCES 1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant PressureBoundary Leakage Detection Systems," May 1973.

3. FSAR, Section [1.

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TSTF-513, Rev. 3




LCO 3.4.15 [Two of] the following RCS leakage detection instrumentation shall beOPERABLE:

a. One containment sump monitor,

b. One containment atmosphere radioactivity monitor (gaseous orparticulate), and

[c. One containment air cooler condensate flow rate monitor.]

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS


A. ,e,4i-ed-CGontainment A.1 ---------- NOTE-------sump monitor Not required until 12 hoursinoperable, after establishment of



AND

A.2 Restore containment sump 30 daysmonitor to OPERABLEstatus.

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TSTF-513, Rev. 3


ACTIONS (continued)


B. Required containment B1.1 Analyze grab samples of Once per 24 hoursatmosphere radioactivity the containmentmonitor inoperable, atmosphere.

OR

B.1.2 --------- NOTE --------------Not required until 12 hoursafter establishment ofsteady state operation.


AND

B.2.1 Restore required 30 dayscontainment atmosphereradioactivity monitor toOPERABLE status.

OR

LB.2.2 [-Verify containment air 30 days ]cooler condensate flow ratemonitor is OPERABLE.

C. [Requife4-CGontainment C.1 NOTEair cooler condensate Not required until 12 haursflow rate monitor after establishment otinoperable. steady state operation.


OR

C.2 ---------- NOTE-------Not required until 12 hoursafter establishment ofsteady state operation.

Perform SR 3.4.13.1. Once per 24 hours]

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TSTF-513, Rev. 3


ACTIONS (continued)


-NOTE -------------- D.1 Analyze grab samples of Once per 12 hoursOnly applicable when the the containmentcontainment atmosphere atmosphere.gaseous radiation monitor isthe only OPERABLE ANDmonitor.

D.2.1 Restore containment sump 7 daysmonitor to OPERABLE

D. Containment sump status.monitor inoperable.

ORAND

[D.2.2 Restore containment air 7 days 1f Containment air cooler cooler condensate flow ratecondensate flow rate monitor to OPERABLEmonitor inoperable.1 status.

DE.[ Required containment ED.1 Restore required 30 daysatmosphere radioactivity containment atmospheremonitor inoperable, radioactivity monitor to

OPERABLE status.AND

ORjReq4ied-Ceontainmentair cooler condensate [lE.2 Restore FequiFed 30 days]flow rate monitor containment air coolerinoperable.1 condensate flow rate

monitor to OPERABLEstatus.1

FE. Required Action and FE.1 Be in MODE 3. 6 hoursassociated CompletionTime not met. AND

FE.2 Be in MODE 5. 36 hours

GF.AII required monitors GF.1 Enter LCO 3.0.3. Immediately.inoperable.


CEOG STS 3.4.15-3 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3




BASES

BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means fordetecting and, to the extent practical, identifying the location of the sourceof RCS LEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2)describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significantreactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to agross failure. Thus, an early indication or warning signal is necessary topermit proper evaluation of all unidentified LEAKAGE. [In addition tomeeting the OPERABILITY requirements, the monitors are typically set toprovide the most sensitive response without causing an excessivenumber of spurious alarms.1nu... . .be fS u iu 1r s.. . . 1...

,,st,' ' practice has shown. that water flow changes of 0.5 gpm to1.0 gpm can readily be detected in contai*ned volu mes, by moenitorinc.-.I.-. t in. . 4::U level, ::- i,.W ;-W, OF R. W.e. ope;aiL.. :rgquency OT apump. The containment sump used to collect unidentified LEAKAGE [is]o[or) and the containment air cooler condensate flow rate monitor] [are]

instrumented to alarm for increases of 0.5 gpm to 1.0 ,g,,m above in thenormal flow rates. This sen.sitiVity i- acceptable for detecting increases inunidentified IEAKA.GE.

The reactor coolant contains radioactivity that, when released to thecontainment, may ea44-be detected by radiation monitoringinstrumentation. Reacto cooan radioa-cti,,,ity levels will be low duringinitial reacGtor startulp and for a few9 Weeks th~ereafter u ntil nctiva;tocorrosion pF~--rodutsi h-ave ee fo4-FNrmd- and fission products, appear fromful-- ele-.tmet cladding contamnination Or cladding defecots. Ins;trumeFntsensitivities Of 10-0 P~iicc radioactivity for particulae moitoin andI o10Q P(i/cc radioactivity forF gaseous mnonitoring are practical for theseleakage detection systems6. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities, because of theirsensitivities and rapid responses to RCS LEAKAGE.

Other indications may be used to detect an increase in unidentifiedLEAKAGE: however, they are not required to be OPERABLE by thisLCO. An increase in humidity of the containment atmosphere wouldindicate release of water vapor to the containment. Dew pointtemperature measurements can thus be used to monitor humidity levelsof the containment atmosphere as an indicator of potential RCSLEAKAGE. 'A *10F iceaei dew point is- well1 wifthin the sensitivity range

o v iable intrument.v v. v,,••, ,vv,,v,

CEOG STS B 3.4.15-1 Rev. 3.0, 03/31/04CEOG STS B 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES


Since the humidity level is influenced by several factors, a quantitativeevaluation of an indicated leakage rate by this means may bequestionable and should be compared to observed increases in liquidflow into or from the containment sump [and condensate flow from aircoolers]. Humidity level monitoring is considered most useful as anindirect alarm or indication to alert the operator to a potential problem.Humidity monitors are not required by this LCO.

Air temperature and pressure monitoring methods may also be used toinfer unidentified LEAKAGE to the containment. Containmenttemperature and pressure fluctuate slightly during plant operation, but arise above the normally indicated range of values may indicate RCSLEAKAGE into the containment. The relevance of temperature andpressure measurements ae-is__affected by containment free volume and,for temperature, detector location. Alarm signals from these instrumentscan be valuable in recognizing rapid and sizable leakage to thecontainment. Temperature and pressure monitors are not required by-this LCO.

The above-mentioned LEAKAGE detection methods or systems differ insensitivity and response time. [Some of these systems could serve asearly alarm systems signalincq the operators that closer examination ofother detection systems is necessary to determine'the extent of anycorrective action that may be required.]

APPLICABLE The need to evaluate the severity of an alarm or an indication is importantSAFETY to the operators, and the ability to compare and verify with indicationsANALYSES from other systems is necessary. The sy•stem rFespons times . and

sesiivtisare descri bed ithESR(e.3). Multiple instrumentlocations are utilized, if needed, to ensu. r the trn#sport delay time of the,LEAKAGE-= fromFits- sorce- to an ins-trument Iocation R;yields an acceptableoVerall response tiFm.

The safety significance of RCS LEAKAGE varies widely depending on itssource, rate, and duration. Therefore, detecting and monitoring RCSLEAKAGE into the containment area are necessary. Quickly separatingthe identified LEAKAGE from the unidentified LEAKAGE providesquantitative information to the operators, allowing them to take correctiveaction should leakage occur detrimental to the safety of the facility andthe public.


CEOG STS B 3.4.15-2 Rev. 3.0, 03/31/04

CEOG STS B 3.4.15-2 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES

LCO One method of protecting against large RCS, LEAKAGE derives from theability Of iOnr.umentS to rapidly detect •tre small leaks&. This LCOrequires instruments of diverse monitoring principles to be OPERABLE toprovide a high degree -fconfidence that small amounts of unidentifiedLEAKAGE extremely small leaks are detected in time to allow actions toplace the plant in a safe condition when RCS LEAKAGE indicatespossible RCPB degradation.

The LCO requires [threel instruments to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE. [Thecontainment sump consists of the normal sump and the emergencysump. The LCO requirements apply to the total amount of unidentifiedLEAKAGE collected in [the][both] sump[sl.l The monitor on thecontainment sump detects [level or flow rate or the operating frequency ofa pumpi and is instrumented to detect when there is [leakage of] [anincrease above the normal value bvl 1 gpm. The identification of [anincrease inl unidentified LEAKAGE will be delayed by the time requiredfor the unidentified LEAKAGE to travel to the containment sump and itmay take longer than one hour to detect a 1 qpm increase in unidentifiedLEAKAGE, depending on the origin and magnitude of the LEAKAGE.This sensitivity is acceptable for containment sump monitorOPERABILITY.

The reactor coolant contains radioactivity that, when released to thecontainment, can be detected by the gaseous or particulate containmentatmosphere radioactivity monitor. Only one of the two detectors isrequired to be OPERABLE. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE, but have recognizedlimitations. Reactor coolant radioactivity levels will be low during initialreactor startup and for a few weeks thereafter, until activated corrosionproducts have been formed and fission products appear from fuelelement cladding contamination or cladding defects. If there are few fuelelement cladding defects and low levels of activation products, it may notbe possible for the gaseous or particulate containment atmosphereradioactivity monitors to detect a 1 gpm increase within 1 hour duringnormal operation. However, the gaseous or particulate containmentatmosphere radioactivity monitor is OPERABLE when it is capable ofdetecting a 1 qpm increase in unidentified LEAKAGE within 1 hour givenan RCS activity equivalent to that assumed in the design calculations forthe monitors (Reference 3).

[An increase in humidity of the containment atmosphere could indicatethe release of water vapor to the containment. Condensate flow from aircoolers is instrumented to detect when there is an increase above thenormal value by 1 qpm. The time required to detect a 1 qpm increaseabove the normal value varies based on environmental and system

CEOG STS B 3.4.15-3 Rev. 3.0, 03/31/04

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TSTF-513, Rev. 3


conditions and may take longer than 1 hour. This sensitivity is acceptablefor containment air cooler condensate flow rate monitor OPERABILITY.1

The LCO is satisfied when monitors of diverse measurement means areavailable. Thus, the containment sump monitor, in combination with aparticulate or gaseous radioactivity monitor [and a containment air coolercondensate flow rate monitor], provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure. in MODES 1, 2, 3,and 4, RCS leakage detection instrumentation is required'to beOPERABLE.

In MODE 5 or 6, the temperature is < 200°F and pressure is maintainedlow or at atmospheric pressure. Since. the temperatures and pressuresare far lower than those for MODES 1, 2, 3, and 4, the likelihood ofleakage and crack propagation is much smaller. Therefore, therequirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2

If the containment sump monitor is inoperable, no other form of samplingcan provide the equivalent information.

However, the containment atmosphere radioactivity monitor will provideindications of changes in leakage. Together with the containmentatmosphere radioactivity monitor, the periodic surveillance for RCS waterinventory balance, SR 3.4.13.1, must be performed at an increasedfrequency of 24 hours toprovide information that is adequate to detectleakage. A Note is added allowing that SR 3.4.13.1 is not required to beperformed until 12 hours after establishing steady state operation (stabletemperature, power level, pressurizer and makeup tank levels, makeupand letdown, and [RCP seal injection and return flows]). The 12 hourallowance provides sufficient time to collect and process all necessarydata after stable plant conditions are established.

Restoration of the sump monitor to OPERABLE status is required toregain the function in a Completion Time of 30 days after the monitor'sfailure. This time is acceptable considering the frequency and-adequacyof the RCS water inventory balance required by Required Action A.1.


TSTF-513, Rev. 3


BASES

ACTIONS (continued)

B.1.1, B.1.2, B.2.1, and B.2.2

With both gaseous and particulate containment atmosphere radioactivitymonitoring instrumentation channels inoperable, alternative action isrequired. Either grab samples of the containment atmosphere must betaken and 'analyzed, or water inventory balances, in accordance withSR 3.4.13.1, must be performed to provide alternate periodic information.With a sample obtained and analyzed or an inventory balance performedevery 24 hours, the reactor may be operated for up to 30 days to allowrestoration of at least one of the radioactivity monitors.

JAlternatively, continued operation is allowed if the air cooler condensateflow rate monitoring system is OPERABLE, provided grab samples aretaken or water inventory balance performed every 24 hours.]

The 24 hour interval provides periodic information that is adequate todetect leakage. A Note is added allowing that SR 3.4.13.1 is not requiredto be performed until 12 hours after establishing steady state operation(stable temperature, power level, pressurizer and makeup tank levels,makeup and letdown, and [RCP seal injection and return flows]). The12 hour allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established. The 30 dayCompletion Time recognizes at least one other form of leakage detectionis available.

C.1 and C.2

If the r-equir-edcontainment air cooler condensate flow rate monitor isinoperable, alternative action is again required. Either SR 3.4.15.1 mustbe performed, or water inventory balances, in accordance withSR 3.4.13.1, must be performed to provide alternate periodic information.Provided a CHANNEL CHECK is performed every 8 hours or an inventorybalance is performed every 24 hours, reactor operation may continuewhile awaiting restoration of the containment air cooler condensate flowrate monitor to OPERABLE status.

The 24 hour interval provides periodic information that is adequate todetect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is notrequired to be performed until 12 hours after establishing steady stateoperation (stable temperature, power level, pressurizer and makeup tanklevels, makeup and letdown, and [RCP seal injection and return flows]).The 12 hour allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established.


TSTF-513, Rev. 3


BASES

ACTIONS (continued)

D.1, D.2.1, and D.2.2

With the containment sump monitor, [and the containment air coolercondensate flow rate monitor] inoperable, the only means of detectingLEAKAGE is the required containment atmosphere radiation monitor. ANote clarifies that this Condition is applicable when the only OPERABLEmonitor is the containment atmosphere gaseous radiation monitor. Thecontainment atmosphere gaseous radioactivity monitor typically cannotdetect a 1 qpm leak within one hour when RCS activity is low. In addition,this configuration does not provide the required diverse means of leakagedetection. Indirect methods of monitoring RCS leakage must beimplemented. Grab samples of the containment atmosphere must betaken and analyzed must be performed every 12 hours to providealternate periodic information. The 12 hour interval is sufficient to detectincreasing RCS leakage. The Required Action provides 7 days to restoreanother RCS leakage monitor to OPERABLE status to regain theintended leakage detection diversity. The 7 day Completion Timeensures that the plant will not be operated in a degraded configuration fora lengthy time period.

E9.1 and E9.2

If the required containment atmosphere radioactivity monitor [and thecontainment air cooler condensate flow rate monitori are inoperable, theonly means of detecting leakage is the containment sump monitor. ThisCondition does not provide the required diverse means of leakagedetection. The Required Action is to restore either of the inoperablemonitors to OPERABLE status within 30 days to regain the intendedleakage detection diversity. The 30 day Completion Times ensure thatthe plant will not be operated in a reduced configuration for a lengthy timeperiod.]

FE.1 and FE.2

If any Required Action of Condition A, B, [C], JDj or LED] cannot be metwithin the required Completion Time, the plant must be brought to aMODE in which the LCO does not apply. To achieve this status, the plantmust be brought to at least MODE 3 within 6 hours and to MODE 5 within36 hours. The allowed Completion Times are reasonable, based onoperating experience, to reach the required plant conditions from fullpower conditions in an orderly manner and without challenging plantsystems.

FG. 1

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If all required monitors are inoperable, no automatic means of monitoringleakage are available and immediate plant shutdown in accordance withLCO 3.0.3 is required.


SR 3.4.15.1 requires the performance of a CHANNEL CHECK of therequired containment atmosphere radioactivity monitors. The check givesreasonable confidence the channel is operating properly. The Frequencyof [12] hours is based on instrument reliability and is reasonable fordetecting off normal conditions.


TSTF-513, Rev. 3


BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2

SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONALTEST of the required containment atmosphere radioactivity monitors.The test ensures that the monitor can perform its function in the desiredmanner. The test verifies the alarm setpoint and relative accuracy of theinstrument' string. A successful test of the required contact(s) of achannel relay may be performed by the verification of the change of stateof a single contact of the relay. This clarifies what is an acceptableCHANNEL FUNCTIONAL TEST of a relay. This is acceptable becauseall of the other required contacts of the relay are verified by otherTechnical Specifications and non-Technical Specifications tests at leastonce per refueling interval with applicable extensions. The Frequency of92 days considers instrument reliability, and operating experience hasshown it proper for detecting degradation.

SR 3.4.15.3. SR 3.4.15.4, and [SR 3.4.15.51

These SRs require the performance of a CHANNEL CALIBRATION foreach of the RCS leakage detection instrumentation channels. Thecalibration verifies the accuracy of the instrument string, including theinstruments located inside'containment. The Frequency of [18] months isa typical refueling cycle and considers channel reliability. Operatingexperience has shown this Frequency is acceptable.



3. FSAR, Section [1.

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LCO 3.4.15 The following RCS leakage detection instrumentation shall be

OPERABLE:

a. One containment sump (level or discharge flow) monitor,

b. One containment atmosphere'radioactivity monitor (gaseous orparticulate), and

[c. One containment air cooler condensate flow rate monitor.]

APPLICABILITY:

ACTIONS

MODES 1, 2, 3, and 4.


A. Required containment A.1 --------- NOTE-------sump monitor Not required until 12 hoursinoperable, after establishment of



AND

A.2 Restore required 30 dayscontainment sump monitorto OPERABLE status.

WOG STS 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


ACTIONS (continued)


B. Required containment B.1.1 Analyze grab samples of Once per 24 hoursatmosphere radioactivity the containmentmonitor inoperable. atmosphere.

OR

B.1.2 --------- NOTE --------------Not required until 12 hoursafter establishment ofsteady state operation.


f-AND

B.2.1 Restore required 30 dayscontainment atmosphereradioactivity monitor toOPERABLE status.

OR

LB.2.2 Verify containment air 30 days]cooler condensate flow ratemonitor is OPERABLE.

C. [-Requiied--Containment C.A Perform SR 3.4.15.1. Once per 8 hoursair cooler condensateflow rate monitor ORinoperable.

C.2 --------- NOTE --------------Not required until 12 hoursafter establishment ofsteady state operation.


WOG STS 3.4.15-2 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


ACTIONS (continued)


-NOTE D. 1 Analyze -grab samples of Once per 12 hoursOnly applicable when the the containmentcontainment atmosphere atmosphere.gaseous radiation monitor isthe only OPERABLE ANDmonitor.

D.2.1 Restore required 7 dayscontainment sump monitor

D. Required containment to OPERABLE status.sump monitorinoperable. OR

AND [D.2.2 Restore containment air 7 days 1cooler condensate flow rate

Containment air cooler monitor to OPERABLEcondensate flow rate status.monitor inoperable.1

9E.[ Required containment DE.1 Restore required 30 daysatmosphere radioactivity containment atmospheremonitor inoperable, radioactivity monitor to

OPERABLE status.AND

ORLRan,-e -CContainmentair cooler condensate LQE.2 Restore requi-ed 30 days]flow rate monitor containment air coolerinoperable.] condensate flow rate

monitor to OPERABLEstatus.1

F_-. Required Action and FE. 1 Be in MODE 3. 6 hoursassociated CompletionTime not met. AND

FE.2 Be in MODE 5. 36 hours

GF.AII required monitors GF._1 Enter LCO 3.0.3. Immediatelyinoperable.

WOG STS 3.4.15-3 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3




BASES

BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means fordetecting and, to the extent practical, identifying the location of the sourceof RCS LEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2) describesacceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significantreactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to agross failure. Thus, an early indication or warning signal is necessary topermit proper evaluation of all unidentified LEAKAGE. [In addition tomeeting the OPERABILITY requirements, the monitors are typically set toprovide the most sensitive response without causing an excessivenumber of spurious alarms.1

Ilndusr', practie- hars shown that water flow change• s of 0-5 to 1.0 gp mcan be readily detected in contained volumes by mon~itoring chane inwater level, in flow rate, Or in the operating frequenc- of . pump. Thecontainment sump used to collect unidentified LEAKAGE [is] [(or) and thecontainment air cooler condensate flow rate monitor] [are] instrumented toalarm for increases of 0.5 to 1.0 gpm i.-.above the normal flow rates. J-hissensiiiyi accoptable for detecting inrse iundtiedLAKAGE.

The reactor coolant contains radioactivity that, when released to thecontainment, Ga¢•-May be detected by radiation monitoringinstrumentation. Reato,.r coola I•'Rnt radifo"arctiity levels will be loW du6riniitial reactor startup and fogr a few weeks; theare-after, until activate

corrsio prducts have bhe-en formed- and fission products appear fromfuel, elmonlt cladding conta-m~inatfionA or cladding defectsg. Instrumentse.nst.ivitie•.s of 10- .C/cc r,-,-,adioactivity for pa..i""t moni.tori and ot

,.0 p..... radioactivity fo gaseous monitoring are prFactiGa for theseleakage detection systems. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE.

Other indications may be used to detect an increase in unidentifiedLEAKAGE; however, they are not required to be OPERABLE by thisLCO. An increase in humidity of the containment atmosphere wouldindicate release of water vapor to the containment. Dew pointtemperature measurements can thus be used to monitor humidity levelsof the containment atmosphere as an indicator of potential RCSLEAKAGE. A ir dew point i well wh the sensitiVity, ange

WOG STS B 3.4.15-1 Rev. 3.0, 03/31/04WOG STS B 3.4.15-1 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES


Since the humidity level is influenced by several factors, a quantitativeevaluation of an indicated leakage rate by this means may bequestionable and should be compared to observed increases in liquidflow into or from the containment sump [and condensate flow from aircoolers]. Humidity level monitoring is considered most useful as anindirect alarm or indication to alert the operator to a potential problem.Humidity monitors are not required by this LCO.

Air temperature and pressure monitoring methods may also be used toinfer unidentified LEAKAGE to the containment. Containmenttemperature and pressure fluctuate slightly during plant operation, but arise above the normally indicated range of values may indicate RCSleakage into the containment. The relevance of temperature andpressure measurements at-e-is affected by containment free volume and,for temperature, detector location. [Alarm signals from these instrumentscan be valuable in recognizing rapid and sizable leakage to thecontainment. Temperature and pressure monitors are not required bythis LCO.1

The above-mentioned LEAKAGE detection methods or systems differ insensitivity and response time. [Some of these systems could serve asearly alarm systems signaling the operators that closer examination ofother detection systems is necessary to determine the extent of anycorrective action that may be required.1

APPLICABLE The need to evaluate the severity of an alarm or an indication is importantSAFETY to the operators, and the ability to compare and verify with indicationsANALYSES from other systems is necessary. The s,,'stem response times apnd

enstivtie ;are descriehd in the ESAR (Ref. 3). Multiple isrmnlocations are utilized, if needed, to ensure that the tranrsport delay tIme-ofthe leakage fromn its- soQurc-e to an isrmnloaonyields an acceptableeverall response time.

The safety significance of RCS LEAKAGE varies widely depending on itssource, rate, and duration. Therefore, detecting and monitoring RCSLEAKAGE into the containment area is necessary. Quickly separatingthe identified LEAKAGE from the unidentified LEAKAGE providesquantitative information to the operators, allowing them to take correctiveaction should a leakage occur detrimental to the safety of the unit and thepublic.

RCS leakage detection instrumentation satisfies Criterion 1 of10 CFR 50.36(c)(2)(ii).'

LCO One method of protecting against large RCS leakage de;ri.e from, theability of instruments to rapidly detect etremely s.mal lea;ks. This LCO

WOG STS B 3.4.15-2 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


requires instruments of diverse monitoring principles to be OPERABLE toprovide a high degre confidence that small amounts of unidentifiedLEAKAGE extremely eMall leaks are detected in time to allow actions toplace the plant in a safe condition, when RCS LEAKAGE indicatespossible RCPB degradation.

WOG STS B 3.4.15-3 Rev. 3.0, 03/31/04WOG STS B 3.4.15-3 Rev. -3.0, 03/31/04

TSTF-513, Rev. 3


BASES

LCO (continued)


The containment sump is used to collect unidentified LEAKAGE. [Thecontainment sump consists of the normal sump and the emerqencysump. The LCO requirements apply to the total amount of unidentifiedLEAKAGE collected in [thel[bothl sump[s].1 The monitor on thecontainment sump detects [level or flow rate or the operatinq frequency ofa pumpi and is instrumented to detect when there is [leakaqe of] [anincrease above the normal value byl 1 qpm. The identification of [anincrease inl unidentified LEAKAGE will be delayed by the time requiredfor the unidentified LEAKAGE to travel to the containment sump and itmay take lonqer than one hour to detect a 1 qpm increase in unidentifiedLEAKAGE, dependinq on the oriqin and maqnitude of the LEAKAGE.This sensitivity is acceptable for containment sump monitorOPERABILITY.

The reactor coolant contains radioactivity that, when released to thecontainment, can be detected by the qaseous or particulate containmentatmosphere radioactivity monitor. Only one of the two detectors isrequired to be OPERABLE. Radioactivity detection systems are includedfor monitorinq both particulate and qaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE, but have recognizedlimitations. Reactor coolant radioactivity levels will be low durinq initialreactor startup and for a few weeks thereafter, until activated corrosionproducts have been formed and fission products appear from fuelelement claddinq contamination or cladding defects. If there are few fuelelement cladding defects and low levels of activation products, it may notbe possible for the qaseous or particulate containment atmosphereradioactivity monitors to detect a 1 qpm increase within 1 hour durinqnormal operation. However, the qaseous or particulate containmentatmosphere radioactivity monitor is OPERABLE when it is capable ofdetecting a 1 qpm increase in unidentified LEAKAGE within 1 hour givenan RCS activity equivalent to that assumed in the desiqn calculations forthe monitors (Reference 3).

[An increase in humidity of the containment atmosphere could indicatethe release of water vapor to the containment. Condensate flow from aircoolers is instrumented to detect when there is an increase above thenormal value by 1 qpm. The time required to detect a 1 qpm increaseabove the normal value varies based on environmental and systemconditions and may take longer than 1 hour. This sensitivity is acceptablefor containment air cooler condensate flow rate monitor OPERABILITY.1

The LCO is satisfied when monitors of diverse measurement means areavailable. Thus, the containment sump monitor, in combination with a

WOG STS B 3.4.15-4 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


gaseous or particulate radioactivity monitor [and a containment air coolercondensate flow rate monitor], provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3,and 4, RCS leakage detection instrumentation is required to beOPERABLE.

In MODE 5 or 6, the temperature is to be < 200°F and pressure ismaintained low or at atmospheric pressure. Since the temperatures andpressures are far lower than those for MODES 1, 2, 3, and 4, thelikelihood of leakage and crack propagation are much smaller. Therefore,the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2

With the required containment sump monitor inoperable, no other form ofsampling can provide the equivalent information; however, thecontainment atmosphere radioactivity monitor will provide indications ofchanges in leakage. Together with the containment atmosphereradioactivity monitor, the periodic surveillance for RCS water inventorybalance, SR 3.4.13.1, must be performed at an increased frequency of24 hours to provide information that is adequate to detect leakage. ANote is added allowing that SR 3.4.13.1 is not required to be performeduntil 12 hours after establishing steady state operation (stabletemperature, power level, pressurizer and makeup tank levels, makeupand letdown, [and RCP seal injection and return flows]). The 12 hourallowance provides sufficient time to collect and process all necessarydata after stable plant conditions are established.

Restoration of the required sump monitor to OPERABLE status within aCompletion Time of 30 days is required to regain the function after themonitor's failure. This time is acceptable, considering the Frequency andadequacy of the RCS water inventory balance required by RequiredAction A. 1.

WOG STS B 3.4.15-5 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES

ACTIONS (continued)

B.1.1, B.1.2, B.2.1, and B.2.2

With both gaseous and particulate containment atmosphere radioactivitymonitoring instrumentation channels inoperable, alternative action isrequired. Either grab samples of the containment atmosphere must betaken and analyzed or water inventory balances, in accordance withSR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balanceperformed every 24 hours, the reactor may be operated for up to 30 daysto allow restoration of the required containment atmosphere radioactivitymonitors. [Alternatively, continued operation is allowed if the air coolercondensate flow rate monitoring system is OPERABLE, provided grabsamples are taken or water inventory balances performed every24 hours.]

The 24 hour interval provides periodic information that is adequate todetect leakage. A Note is added allowing that SR 3.4.13.1 is not requiredto be performed until 12 hours after establishing steady state operation(stable temperature, power level, pressurizer and makeup tank levels,makeup and letdown, [and RCP seal injection and return flows]). The 12hour allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established. The 30 dayCompletion Time recognizes at least one other form of leakage detectionis available.

C. 1 and C.2

With the Fequked containment air cooler condensate flow rate monitorinoperable, alternative action is again required. Either SR 3.4.15.1 mustbe performed or water inventory balances, in accordance withSR 3.4.13.1, must be performed to provide alternate periodic information.Provided a CHANNEL CHECK is performed every 8 hours or a waterinventory balance is performed every 24 hours, reactor operation maycontinue while awaiting restoration of the containment air coolercondensate flow rate monitor to OPERABLE status.

The 24 hour interval provides periodic information that is adequate todetect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is notrequired to be performed until 12 hours after establishing steady stateoperation (stable temperature, power level, pressurizer and makeup tanklevels, makeup and letdown, [and RCP seal injection and return flows]).The 12 hour allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established. ]

WOG STS B 3.4.15-6 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES

ACTIONS (continued)

D.1, D.2.1, and D.2.2

With the required containment sump monitor [and the containment aircooler condensate flow rate monitor] inoperable, the only means ofdetecting LEAKAGE is the required containment atmosphere radiationmonitor. A Note clarifies that this Condition is applicable when the onlyOPERABLE monitor is the containment atmosphere gaseous radiationmonitor. The containment atmosphere gaseous radioactivity monitortypically cannot detect a 1 qpm leak within one hour when RCS activity islow. In addition, this configuration does not provide the required diversemeans of leakage detection. Indirect methods of monitoring RCS leakagemust be implemented. Grab samples of the containment atmospheremust be taken to provide alternate periodic information. The 12 hourinterval is sufficient to detect increasing RCS leakage. The RequiredAction provides 7 days to restore another RCS leakage monitor toOPERABLE status to regain the intended leakage detection diversity.The 7 day Completion Time ensures that the plant will not be operated ina degraded configuration for a lengthy time period.

[DE.1 and 9E.2

With the required containment atmosphere radioactivity monitor [and theeqFed containment air cooler condensate flow rate monitori inoperable,

the only means of detecting leakage is the containment sump monitor.This Condition does not provide the required diverse means of leakagedetection. The Required Action is to restore either of the inoperablerequired monitors to OPERABLE status within 30 days to regain theintended leakage detection diversity. The 30 day Completion Timeensures that the plant will not be operated in a reduced configuration for alengthy time period. ]

FE=.1 and FE.2

If a Required Action of Condition A, B, [C], [DJ or [DPE] cannot be met, theplant must be brought to a MODE in which the requirement does notapply, To achieve this status, the plant must be brought to at leastMODE 3 within 6 hours and to MODE 5 within 36 hours. The allowedCompletion Times are reasonable, based on operating experience, toreach the required plant conditions from full power conditions in anorderly manner and without challenging plant systems.

GF.1

WOG STS B 3.4.15-7* Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


With all required monitors inoperable, no automatic means of monitoringleakage are available, and immediate plant shutdown in accordance withLCO 3.0.3 is required.


SR 3.4.15.1 requires the performance of a CHANNEL CHECK of therequired containment atmosphere radioactivity monitor. The check givesreasonable confidence that the channel is operating properly. TheFrequency of 12 hours is based on instrument reliability and is reasonablefor detecting off normal conditions.

WOG STS B 3.4.15-8 Rev. 3.0, 03/31/04WOG STS B 3.4.15-8 Rev. 3.0, 03/31/04

TSTF-513, Rev. 3


BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2

SR 3.4.15.2 requires the performance of a COT on the requiredcontainment atmosphere radioactivity monitor. The test ensures that themonitor can perform its function in the desired manner. A successful testof the required contact(s) of a channel relay may be performed by theverification of the change of state of a single contact of the relay. Thisclarifies what is an acceptable COT of a relay. This is acceptablebecause all of the other required contacts of the relay are verified by otherTechnical Specifications and non-Technical Specifications tests at leastonce per refueling interval with applicable extensions. The test verifiesthe alarm setpoint and relative accuracy of the instrument string. TheFrequency of 92 days considers instrument reliability, and operatingexperience has shown that it is proper for detecting degradation.

SR 3.4.15.3, [SR 3.4.15.4, and SR 3.4.15.51

These SRs require the performance of a CHANNEL CALIBRATION foreach of the RCS leakage detection instrumentation channels. Thecalibration verifies the accuracy of the instrument string, including theinstruments located inside containment. The Frequency of [18] months isa typical refueling cycle and considers channel reliability. Again,operating experience has proven that this Frequency is acceptable.



3. FSAR, Section [ ].

WOG STS B 3.4.15-9 Rev. 3.0, 03/31/04

BWROG-118, Rev. 0 TSTF-514, Rev. 2

Technical Specification Task ForceImproved Standard Technical Specifications Change Traveler

Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation

NUREGsAffected: E] 1430 E] 1431 E] 1432 [] 1433 W 1434

Classification 1) Technical Change Recommended for CLIIP?: Yes

Correction or Improvement: Improvement NRC Fee Status: Exempt

Benefit: Avoids Future Amendments

See attached.

Revision History

OG Revision 0 Revision Status: Closed

Revision Proposed by: BWROG

Revision Description:Original Issue

Owners Group Review InformationDate Originated by OG: 14-Jan-09


Owners Group Resolution: Approved Date: 18-Feb-09


TSTF Received Date: 14-Jan-09 Date Distributed for Review 06-Feb-09

OG Review Completed: [] BWOG [] WOG [] CEOG [] BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 18-Feb-09

NRC Review InformationNRC Received Date: 18-Feb-09

NRC Comments:

Fee exemption granted on 3/30/09.


Revision Proposed by: NRC.

05-Aug-lOTraveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.



Revision Description:TSTF-514 is revised to reflect the industry's response to the NRC's 6/11/2009 Request for AdditionalInformation.

Specific changes are:

1. The Background section of the Bases is revised to include the optional statement, "[In addition to meetingthe OPERABILITY requirements, the monitors are typically set to provide the most sensitive response withoutcausing an excessive number of spurious alarms.]"

2. Proposed Required Action F.2 is revised from, "Monitor RCS leakage by administrative means" to "Verifyno increase in RCS LEAKAGE over pre-established values."

3. The LCO Bases are revised to clarify that the drywell floor drain sump monitoring system is required toquanitify the leakage rate, not leakage.

The justification is revised to reflect these changes.

Owners Group Review InformationDate Originated by OG: 14-Aug-09


Owners Group Resolution: Date:


TSTF Received Date: 14-Aug-09 Date Distributed for Review 14-Aug-09

OG Review Completed: W BWOG [] WOG F] -CEOG W BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 08-Sep-09


NRC Received Date: 08-Sep-09

NRC Comments:

The NRC requested that the TSTF revise the Traveler to remove the change associated with no operable RCSleakage monitoring instrumentation, as that change was not seen as being directly related to the issuedescribed in Regulatory Issue Summary 2009-02, Rev. 1, "Use of Containment Atmosphere GaseousRadioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear PowerReactors," which was the basis for the TSTF's fee waiver request. In a letter dated June 21, 2010, the TSTFvolunteered to pay for the NRC review of the change associated with no Operable RCS leakage monitoringinstrumentation. At the July 15, 2010 TSTF/NRC public meeting, the NRC did not accept the TSTF's offerand requested that the TSTF revise the Traveler to remove the changes. The TSTF agre'ed to revise theTraveler as requested.







Revision Description:The NRC requested that the TSTF revise the Traveler to remove the change associated with no operable RCSleakage monitoring instrumentation, as that change was not seen as being directly related to the issuedescribed in Regulatory Issue Summary 2009-02, Rev. 1, "Use of Containment Atmosphere GaseousRadioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors,"which was the basis for the TSTF's fee waiver request. In a letter dated June 21, 2010, the TSTF volunteeredto pay for the NRC review of the change associated with no Operable RCS leakage monitoringinstrumentation. At the July 15, 2010 TSTF/NRC public meeting, the NRC did not accept the TSTF's offerand requested that the TSTF revise the Traveler to remove the changes. The TSTF agreed to revise theTraveler as requested.

The revision removes the changes to Condition F and the associated change to move Condition E to ConditionG. The associated changes to the Bases are removed, as well as the discussion of the removed changes fromthe justification.

Owners Group Review InformationDate Originated by OG: 23-Jul-10


Owners Group Resolution: Approved Date: 04-Aug-10


TSTF Received Date: 23-Jul-10 Date Distributed for Review 23-Jul-10

OG Review Completed: W BWOG 91 WOG [] CEOG F] BWROG

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 06-Aug-10


NRC Received Date: 06-Aug-10

Affected Technical SpecificationsBkgnd 3.4.6 Bases RCS Leakage. Detection Instrumentation NUREG(s)- 1433 Only

S/A 3.4.6 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only


BWROG-118, Rev. 0 1 STF-514, Rev. 2

LCO 3.4.6 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only

Ref. 3.4.6 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only

Action 3.4.6.C Bases RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only

Change Description: Corrected SR Reference


Change Description: New Action







Action 3.4.6.E RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only


Action 3.4.6.E Bases RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only


Action 3.4.6.F RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only


Bkgnd 3.4.7 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only


S/A 3.4.7 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only

LCO 3.4.7 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only

Ref. 3.4.7 Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only









Action 3.4.7.E RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only


Action 3.4.7.E Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only


05-Aug-JO

Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.


Action 3.4.7.F RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only


Action 3.4.7.F Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only


05-Aug-10Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. NuclearRegulatory Commission is granted. All other use without written permission is prohibited.

TSTF-514, Rev. 2

1.0 Description

NUREG-1433 Specification 3.4.6, "RCS Leakage Detection Instrumentation," andNUREG-1434 Specification 3.4.7 of the same title require instrumentation to detectsignificant reactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to a gross failure. TheImproved Standard Technical Specifications (ISTS) for BWR/4 plants (NUREG-1433)requires one drywell floor drain sump monitoring system, one channel of either primarycontainment atmospheric particulate or atmospheric gaseous monitoring system, and(optionally) a primary containment air cooler condensate flow rate monitoring system.The BWR/6 ISTS (NUREG-1434) requires one drywell floor drain sump monitoringsystem, one channel of either drywell atmospheric particulate or atmospheric gaseousmonitoring system, and (optionally) a drywell air cooler condensate flow rate monitoringsystem.

Questions have been raised regarding the Operability requirements for these instruments.In particular, improvements in plant fuel integrity have resulted in a reduction of theReactor Coolant System (RCS) activity. As a result, the atmospheric radioactivitymonitors may not be capable of promptly detecting an increase in RCS leakage.

The proposed change revises the Bases to clearly define the RCS leakage detectioninstrumentation Operability requirements and to modify the Actions to be taken when theatmospheric gaseous radioactivity monitor is the only Operable monitor to requireadditional, more frequent monitoring of other indications of RCS leakage and to shortenthe time allowed to restore another monitor to Operable status.

2.0 Proposed Chance

The "RCS Leakage Detection Instrumentation," specification (BWR/4 LCO 3.4.6 andBWR/6 LCO 3.4.7) is revised to add a new Condition. New Condition D is applicablewhen the atmospheric gaseous radioactivity monitor is the only Operable monitor (i.e., allother monitors are inoperable). The Required Actions require analyzing grab samples ofthe primary containment (BWR/4) or drywell (BWR/6) atmosphere and monitoring RCSleakage using administrative means every 12 hours and restoring another monitor toOperable status within 7 days. The subsequent Conditions are renumbered to reflect inaddition of the new Condition.

The Bases are revised to clearly define the RCS leakage detection instrumentationOperability requirements in the LCO Bases and to eliminate discussion from the Basesthat could be erroneously construed as Operability requirements. The Bases are alsorevised to reflect the changes to the Technical Specifications and to more accuratelyreflect the existing Technical Specifications.

Also, the primary containment and drywell air cooler condensate flow rate monitor isplant-specific, and therefore bracketed in the NUREG. The specifications and Bases arerevised to consistently bracket references to this monitor.

Page 2

TSTF-514, Rev. 2

3.0 Background

General Design Criterion (GDC) 30 of Appendix A to 10 CFR 50 requires means fordetecting and, to the extent practical, identifying the location of the source of RCSLeakage. Regulatory Guide (RG) 1.45, Revision 0, "Reactor Coolant Pressure BoundaryLeakage Detection Systems," May 1973, describes acceptable methods for selectingleakage detection systems. Revision I of RG 1.45 was issued in May 2008. However,operating nuclear power plants are not committed to Revision I of RG 1.45.

NRC Information Notice (IN) 2005-24, "Non-conservatism in Leakage DetectionSensitivity," (ADAMS Accession No. ML051780073) pointed out that the reactorcoolant activity assumptions used for designing the containment radiation gaseousradiation monitor may be greater than the RCS radioactivity level present during normaloperation. As a result, the containment gas channel may not be able to detect a I gpmleak within I hour at the current RCS radioactivity level.

RG 1.45, Rev. 0, Regulatory Position C.2 states that "Leakage to the primary reactorcontainment from unidentified sources should be collected and the flow rate monitoredwith an accuracy of one gallon per minute (gpm) or better," Regulatory Position C.3states, "At least three separate detection methods should be employed and two of thesemethods should be (1) sump level and flow monitoring and (2) airborne particulateradioactivity monitoring. The third method may be selected from the following: a.monitoring of condensate flow rate from air coolers, b. monitoring of airborne gaseousradioactivity. Humidity, temperature, or pressure monitoring of the containmentatmosphere should be considered as alarms or indirect indication of leakage to thecontainment." Regulatory Position C.5 states, "The sensitivity and response time of eachleakage detection system in regulatory position [C.]3. above employed for unidentifiedleakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in lessthan one hour." RG 1.45, Rev. 0, states, "In analyzing the sensitivity of leak detectionsystems using airborne particulate or gaseous radioactivity, a realistic primary coolantradioactivity concentration assumption should be used. The expected values used in theplant environmental report would be acceptable." Many plants pre-date the issuance ofRG 1.45 and their plant-specific licensing basis is described in their UFSAR. In eithercase, the appropriate sensitivity of the atmospheric radiation monitors is dependent on thedesign assumptions and the plant licensing basis of each licensee.

The ISTS "RCS Leakage Detection Instrumentation" Bases do not clearly define the basisfor Operability for the RCS leakage detection instrumentation. Operability requirementsshould be defined in the LCO section~of the Bases. However, the current Bases containinformation that could be construed as Operability requirements in the Background,Applicable Safety Analysis, and LCO sections. In addition, the current Bases do notaccurately describe the Operability of a detector as being based on the designassumptions and licensing basis for the plant.

Because the atmospheric gaseous radiation monitor cannot always detect an RCS leak ata rate of I gpm within 1 hour, some plants have removed the monitor from the TechnicalSpecification list of required monitors. However, experience has shown that the

Page 3

TSTF-514, Rev. 2

containment atmosphere gaseous radiation monitor is useful to detect an increase in RCSleak rate and provides a diverse means to confirm an RCS leak exists when othermonitors detect an increase in RCS leak rate. Therefore, the preferred solution is to retainthe atmospheric gaseous radiation monitor in the LCO list of required equipment, and torevise the Actions to require additional monitoring and to provide less time before a plantshutdown is required when the atmospheric gaseous radiation monitor is the onlyOperable monitor.

4.0 Technical Analysis

This change will reduce the number of unnecessary MODE changes and requests forenforcement discretion by clarifying the Operability requirements for the RCS leakagedetection instrumentation and by allowing a limited time to repair one or more of theinoperable monitors. A plant shut down solely as a result of the loss of the preferred TSmonitoring capability could be avoided. The use of alternate leakage detectionmonitoring for a limited time is an appropriate response to this condition.

The proposed Bases changes will clarify the Operability' requirements of the RCS leakagedetection instrumentation. All references to RG 1.45 are revised to reference Revision 0of the RG. Information in the Background and Applicable Safety Analysis sections ofthe Bases that could be construed as Operability requirements is deleted. The LCOsection of the Bases is expanded to provide a detailed discussion of the Operabilityrequirements for each of the required instruments. For the atmospheric radioactivitymonitors, the Bases clearly relate Operability to the design assumptions and licensingbasis for the plant and a reference to the Final Safety Analysis Report description of thedesign basis of the monitors is included.

As described in 10 CFR 50.36(c)(2)(i), the Limiting Condition for Operation andassociated Operability requirements represent the lowest functional capability orperformance levels of equipment required for safe operation of the facility. In practice,the leakage monitoring instrumentation is typically set to provide the most sensiti'eresponse without distracting the reactor operators with unnecessary alarms.

When the atmospheric gaseous radiation monitor is the only Operable monitor, thecurrent Technical Specifications require grab samples of the primary containment ordrywell atmosphere once per 12 hours and restoration of the inoperable monitors within30 days. The proposed change requires analyzing grab samples from the primarycontainment or drywell atmosphere and monitoring RCS leakage by administrativemeans once per 12 hours and restoration of at least one additional monitor within 7 days.

Administrative means of monitoring RCS leakage include monitoring and trendingparameters that may indicate an increase in RCS leakage. There are diverse alternativemechanisms from which appropriate indicators may be selected based on plant conditions.It is not necessary to utilize all of these methods, but a method or methods should beselected considering the current plant conditions and historical or expected sources ofunidentified leakage. The administrative methods include, but are not limited to, primarycontainment and drywell pressure, temperature, and humidity, Component Cooling Water

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TSTF-514, Rev. 2

System outlet temperatures and makeup, Reactor Recirculation System pump sealpressure and temperature and motor cooler temperature indications, Drywell cooling fanoutlet temperatures, Reactor Building Chiller amperage, Control Rod Drive Systemflange temperatures, and Safety Relief Valves tailpipe temperature, flow, or pressure.These indications, coupled with the atmospheric grab samples, are sufficient to alert theoperating staff to an unexpected increase in unidentified LEAKAGE.

A primary containment or drywell grab sample is comparable to the atmosphericparticulate radiation monitor with respect to the ability to detect RCS leakage. Due to thetime to take and analyze the grab sample, this is not a continuous monitoring method.However, the frequent performance of the grab samples ensures there is no significantloss of monitoring capability during the limited time period allowed by the proposedchange. The 12 hour (once per shift) performance of primary containment or drywellgrab samples and monitoring by administrative means is reasonable given the availabilityof the atmospheric gaseous radiation monitor. The 7 day Completion Time to restoreanother monitor to Operable status is reasonable given the diverse methods employed inthe Required Actions to detect an RCS leak and the low probability of a large RCS leakduring this period.

5.0 Regulatory Analysis

5.1 No Significant Hazards Consideration

The Technical Specification Task Force (TSTF) has evaluated whether or not a

significant hazards consideration is involved with the proposed generic change byfocusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," asdiscussed below:

I. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable.RCS leakage detectioninstrumentation monitor is the atmospheric gaseous radiation monitor. Themonitoring of RCS leakage is not a precursor to any accident previously evaluated.The monitoring of RCS leakage is not used to mitigate the consequences of anyaccident previously evaluated.

Therefore, it is concluded that this change does not involve a significant increasein the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

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TSTF-514, Rev. 2

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable RCS leakage detectioninstrumentation monitor is the atmospheric gaseous radiation monitor. Theproposed change does not involve a physical alteration of the plant (no new ordifferent type of equipment will be installed) or a change in the methodsgoverning normal plant operation.

Therefore, it is concluded that this change does not create the possibility of a newor different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the Operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation and reduces the timeallowed for the plant to operate when the only Operable RCS leakage detectioninstrumentation monitor is the atmospheric gaseous radiation monitor. Reducingthe amount of time the plant is allowed to operate with only the atmosphericgaseous radiation monitor Operable increases the margin of safety by increasingthe likelihood that an increase in RCS leakage will be detected before itpotentially results in gross failure.

Therefore, it is concluded that this change does not involve a significant reductionin a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significanthazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly,a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria

10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion30, "Quality of reactor coolant pressure' boundary," requires that means be provided fordetecting and, to the extent practical, identifying the location of the source of reactorcoolant leakage. The specific attributes of the reactor coolant leakage detection systemsare outlined in Regulatory Positions 1 through 9 of Regulatory Guide 1.45, Rev. 0.

10 CFR 50.36, "Technical Specifications," paragraph (c)(2)(ii)(A), specifies that aLimiting Condition for Operation be established for installed instrumentation that is usedto detect and indicate in the control room a significant abnormal degradation of thereactor coolant pressure boundary. This instrumentation is required by the "RCSLeakage Detection Instrumentation" Specification. The modification of the Actions inthe Specification is not in conflict with the 10 CFR 50.36 requirements. The proposed

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TSTF-514, Rev. 2

changes do not adversely impact the ability of the Reactor Coolant System leakagedetection system to function as designed and do not impact conformance to the applicableGDCs. Therefore, the proposed changes are consistent with all applicable regulatoryrequirements or criteria.

Based on the considerations discussed above, (1) there is reasonable assurance that thehealth and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission'sregulations, and (3) the approval of the proposed change will not be inimical to thecommon defense and security or to the health and safety of the public.

6.0 Environmental Consideration

A review has determined that the proposed change would change a requirement withrespect to installation or use of a facility component located within the restricted area, asdefined in 10 CFR 20, or would change an inspection or surveillance requirement.However, the proposed change does not involve (i) a significant hazards consideration, (ii)a significant change in the types or significant increase in the amounts of any effluent thatmay be released offsite, or (iii) a significant increase in individual or cumulative'occupational radiation exposure. Accordingly, the proposed change meets the eligibilitycriterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to10 CFR 51.22(b), no environmental impact statement or environmental assessment needbe prepared in connection with the proposed change.

7.0 References

None.

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LCO 3.4.6 The following RCS leakage detection instrumentation shall beOPERABLE:

a. Drywell floor drain sump monitoring system, [and]

b. One channel of either primary containment atmospheric particulateor atmospheric gaseous monitoring system, and

[c. Primary containment air cooler condensate flow rate monitoringsystem. ]

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS


A. Drywell floor drain sump A.1 Restore drywell floor drain 30 daysmonitoring system sump monitoring system toinoperable. OPERABLE status.

B. Required primary B.1 Analyze grab samples of Once per 12 hourscontainment primary containmentatmospheric monitoring atmosphere.system inoperable.

AND

"B.2 [Restore required primary 30 days]containment atmosphericmonitoring system toOPERABLE status.

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ACTIONS (continued)


C. [ Primary containment C.1 --------- NOTE-------air cooler condensate Not applicable whenflow rate monitoring required primarysystem inoperable, containment atmospheric

monitoring system isinoperable.


-NOTE D. 1 Analyze grab samples of Once per 12 hoursOnly applicable when the the primary containmentprimary containment atmosphere.atmospheric gaseousradiation monitor is the only ANDOPERABLE monitor.

D.2 Monitor RCS LEAKAGE by Once-per 12 hoursadministrative means.

D. Drywell floor drain sumpmonitoring system ANDinoperable.

D.3.1 Restore drywell floor drain 7 daysAND sump monitoring system to

OPERABLE status.[Primary containment aircooler condensate flow ORrate monitoring systeminoperable.1 [ D.3.2 Restore primary 7 days 1

containment air coolercondensate flow ratemonitoring system toOPERABLE status.

ED.[ Required primary ED.1 Restore required primary 30 dayscontainment containment atmosphericatmospheric monitoring monitoring system tosystem inoperable. OPERABLE status.

AND OR

Primary containment air ED.2 Restore primary 30 days ]cooler condensate flow containment air coolerrate monitoring system condensate flow rate

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inoperable, monitoring system toOPERABLE status.

FE. Required Action and FE. 1 Be in MODE 3. 12 hoursassociated CompletionTime of Condition A, B, AND[C, D, or ED] not met.

FE-.2 Be in MODE 4. 36 hours

GF..AII required leakage GF._ Enter LCO 3.0.3. Immediatelydetection systemsinoperable.

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BASES

BACKGROUND GDC 30 of 10 CFR 50, Appendix A (Ref. 1), requires means for detectingand, to the extent practical, identifying the location of the source of RCSLEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2) describesacceptable methods for selecting leakage detection systems.

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB)are required so that appropriate action can be taken before the integrity ofthe RCPB is impaired (Ref. 2). Leakage detection systems for the RCSare provided to alert the operators when leakage rates above normalbackground levels are detected and also to supply quantitativemeasurement of leakage rates. [In addition to meeting theOPERABILITY requirements, the monitors are typically set to provide themost sensitive response without causing an excessive number ofspurious alarms.j The Bases for LCO 3.4.4, "RCS OperationalLEAKAGE," discuss the limits on RCS LEAKAGE rates.

Systems for separating the LEAKAGE of an identified source from anunidentified source are necessary to provide prompt and quantitativeinformation to the operators to permit them to take immediate correctiveaction.

LEAKAGE from the RCPB inside the drywell is detected by at least one oftwo or three independently monitored variables, such as sump levelchanges and drywell gaseous and particulate radioactivity levels. Theprimary means of quantifying LEAKAGE in the drywell is the drywell floordrain sump monitoring system.

The drywell floor drain sump monitoring system monitors the LEAKAGEcollected in the floor drain sump. This unidentified LEAKAGE consists ofLEAKAGE from control rod drives, valve flanges or packings, floor drains,the Closed Cooling Water System, and drywell air cooling unitcondensate drains, and any LEAKAGE not collected in the drywellequipment drain sump. The primary containment floor drain sump hastransmitters that supply level indications in the main control room.

The floor drain sump level indicators have switches that start and stop thesump pumps when required. A timer starts each time the sump ispumped down to the low level setpoint. If the sump fills to the high levelsetpoint before the timer ends, an alarm sounds in the control room,indicating a LEAKAGE rate into the sump in excess of a preset limit.

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A flow indicator in the discharge line of the drywell floor drain sumppumps provides flow indication in the control room. The pumps can alsobe started from the control room.


TSTF-514, Rev. 2


BASES


The primary containment air monitoring systems continuously monitor theprimary containment atmosphere for airborne particulate and gaseousradioactivity. A sudden increase of radioactivity, which may be attributedto RCPB steam or reactor water LEAKAGE, is annunciated in the controlroom. The primary contaionment atmo.phoro pa.ticulate and gaseousradi•o•tiVity monitoring system. are not capable of .. a.tif,,ing LEAKlA.GZEErates, but aree sensbitive- enough to iniaeicesdLEAKAGE rates ot' gpm within 1 hour. LargeFr hanges in LEAKAGE rates are detected inproportionally shorter times (Ref. 3).

[Condensate from four of the six primary containment coolers is routed tothe primary containment floor drain sump and is monitored by a flowtransmitter that provides indication and alarms in the control room. Thisprimary containment air cooler condensate flow rate monitoring systemserves as an added indicator, but not quantifier, of RCS unidentifiedLEAKAGE. ]

APPLICABLE A threat of significant compromise to the RCPB exists if the barrierSAFETY contains a crack that is large enough to propagate rapidly. LEAKAGEANALYSES rate limits are set low enough to detect the LEAKAGE emitted from a

single crack in the RCPB (Refs. 4-3 and 54). Each of the leakagedetection systems inside the dr-ywell is, designed With the capabiliy otdeteGting LEA.KA•-E les-s than the establishqed I EAI=KAG=E rate limits andproviding appropriate alarm of emxess I EAKAGE in the cntrol raoFm.

A control room alarm allows the operators to evaluate the significance ofthe indicated LEAKAGE and, if necessary, shut down the reactor forfurther investigation and corrective action. The allowed LEAKAGE ratesare well below the rates predicted for critical crack sizes (Ref. 65).Therefore, these actions provide adequate response before a significantbreak in the RCPB can occur.


LCO This LCO requires instruments of diverse monitoring principles to beOPERABLE to provide confidence that small amounts of unidentifiedLEAKAGE are detected in time to allow actions to place the plant in asafe condition, when RCS LEAKAGE indicates possible RCPBdegradation.


The drywell floor drain sump monitoring system is required to quantify theunidentified LEAKAGE rate from the RCS. Thus, for the system to beconsidered OPERABLE, either the flow monitoring or the sump level

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monitoring portion of the system must be OPERABLE and capable ofdetermining the leakage rate. The identification of an increase inunidentified LEAKAGE will be delayed by the time required for theunidentified LEAKAGE to travel to the drywell floor drain sump and it maytake longer than one hour to detect a 1 qpm increase in unidentifiedLEAKAGE, depending on the origin and magnitude of the LEAKAGE.This sensitivity is acceptable for containment sump monitorOPERABILITY.

The reactor coolant contains radioactivity that, when released to theprimary containment, can be detected by the gaseous or particulateprimary containment atmospheric radioactivity monitor. Only one of thetwo detectors is required to be OPERABLE. Radioactivity detectionsystems are included for monitoring both particulate and gaseousactivities because of their sensitivities and rapid responses to RCSLEAKAGE, but have recognized limitations. Reactor coolant radioactivitylevels will be low during initial reactor startup and for a few weeksthereafter, until activated corrosion products have been formed andfission products appear from fuel element cladding contamination orcladding defects. If there are few fuel element cladding defects and lowlevels of activation products, it may not be possible for the gaseous orparticulate primary containment atmospheric radioactivity monitors todetect a 1 qpm increase within 1 hour during normal operation. However,the gaseous or particulate containment primary atmospheric radioactivitymonitor is OPERABLE when it is capable of detecting a 1 qpm increase inunidentified LEAKAGE within 1 hour given an RCS activity equivalent tothat assumed in the design calculations for the monitors (Reference 6).

[An increase in humidity of the containment atmospheric could indicatethe release of water vapor to the containment. Primary containment aircooler condensate flow rate is instrumented to detect when there is anincrease above the normal value by 1 qpm. The time required to detect a1 qpm increase above the normal value varies based on environmentaland system conditions and may take longer than 1 hour. This sensitivityis acceptable for containment air cooler condensate flow rate monitorOPERABILITY.1

The LCO is satisfied when monitors of diverse measurement means areavailable. Thus, the drvwell floor drain sump monitoring system, incombination with a gaseous or particulate primary containmentatmospheric radioactivity monitor [and a primary containment air coolercondensate flow rate monitoring system], provides an acceptableminimum.The dr,'well floor dr~ain su.Mp mon~itoring system is required to quantify theunidentified LEAKAGE frome the RCS. Thus, for the 6ystem to becnspi;dered OPFERABLEF, either the flow monitoring Or the 661ýplelmonitoring portion of the system must be OPERARLE. The ,thormoni*toring Systems provide early alarms to thee perators Go cloer

exmiaton f o-ther deAtoGtion systemsR Will be m~ade to determine thewe~et of any copprrective Rction that mnay be required. With thelekg


TSTF-514, Rev. 2


moniorFing for LEAKA\GE in the RCPB ideteetign 6eystPdegraded.

..r- GA-A-ra~le.

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BASES

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to beOPERABLE to support LCO 3.4.4. This Applicability is consistent withthat for LCO 3.4.4.

ACTIONS A..1

With the drywell floor drain sump monitoring system inoperable, no otherform of sampling can provide the equivalent information to quantifyleakage. However, the primary containment atmospheric activity monitor[and the primary containment air cooler condensate flow rate monitor] willprovide indication of changes in leakage.

With the drywell floor drain sump monitoring system inoperable, but withRCS unidentified and total LEAKAGE being determined every 8 hours(SR 3.4.4.1), operation may continue for 30 days. The 30 dayCompletion Time of Required Action A.1 is acceptable, based onoperating experience, considering the multiple forms of leakage detectionthat are still available.

B.1 and B.2

With both gaseous and particulate primary containment atmosphericmonitoring channels inoperable, grab samples of the primary containmentatmosphere must be taken and analyzed to provide periodic leakageinformation. [Provided a sample is obtained and analyzed once every12 hours, the plant may be operated for up to 30 days to allow restorationof at least one of the required monitors.] [Provided a sample is obtainedand analyzed every 12 hours, the plant may continue operation since atleast one other form of drywell leakage detection (i.e., air coolercondensate flow rate monitor) is available.]

The 12 hour interval provides periodic information that is adequate todetect LEAKAGE. The 30 day Completion Time for restorationrecognizes that at least one other form of leakage detection is available.


TSTF-514, Rev. 2


BASES

ACTIONS (continued)

[C.1

With the required primary containment air cooler condensate flow ratemonitoring system inoperable, SR 3.4.6.1 must be performed every

.8 hours to provide periodic information of activity in the primarycontainment at a more frequent interval than the routine Frequency ofSR 3.4.7-6.1. The 8 hour interval provides periodic information that isadequate to detect LEAKAGE and recognizes that other forms of leakagedetection are available. However, this Required Action is modified by aNote that allows this action to be not applicable if the required primarycontainment atmospheric monitoring system is inoperable. Consistentwith SR 3.0.1, Surveillances are not required to be performed oninoperable equipment.

D.1, D.2, D.3.1, and D.3.2

With the drywell floor drain sump monitoring system [and the primarycontainment air cooler condensate flow rate monitoring system]inoperable, the only means of detecting LEAKAGE is the primarycontainment atmospheric gaseous radiation monitor. A Note clarifies thisapplicability of the Condition. The primary containment atmosphericgaseous radiation monitor typically cannot detect a 1 qpm leak within onehour when RCS activity is low. In addition, this configuration does notprovide the required diverse means of leakage detection. Indirectmethods of monitoring RCS leakage must be implemented. Grabsamples of the primary containment atmosphere must be taken andanalyzed and monitoring of RCS leakage by administrative means mustbe performed every 12 hours to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring andtrending parameters that may indicate an increase in RCS leakage.There are diverse alternative mechanisms from which appropriateindicators may be selected based on plant conditions. It is not necessaryto utilize all of these methods, but a method or methods should beselected considering the current plant conditions and historical orexpected sources of unidentified leakage. The administrative methodsinclude, but are not limited to, primary containment and drywell pressure,temperature, and humidity, Component Cooling Water System outlettemperatures and makeup, Reactor Recirculation System pump sealpressure and temperature and motor cooler temperature indications,Drywell cooling fan outlet temperatures, Reactor Building Chilleramperage, Control Rod Drive System flange temperatures, and SafetyRelief Valves tailpipe temperature, flow, or pressure. These indications,coupled with the atmospheric grab samples, are sufficient to alert theoperating staff to an unexpected increase in unidentified LEAKAGE.

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The 12 hour interval is sufficient to detect increasing RCS leakage. TheRequired Action provides 7 days to restore another RCS leakage monitorto OPERABLE status to regain the intended leakage detection diversity.The 7 day Completion Time ensures that the plant will not be operated ina degraded configuration for a lengthy time period.

[ED.1 and ED.2

With both the primary containment gaseous and particulate atmosphericmonitor channels and the primary containment air cooler condensate flowrate monitor inoperable, the only means of detecting LEAKAGE is thedrywell floor drain sump monitor. This condition does not provide therequired diverse means of leakage detection. The Required Action is torestore either of the inoperable monitors to OPERABLE status within30 days to regain the intended leakage detection diversity. The 30 dayCompletion Time ensures that the plant will not be operated in adegraded configuration for a lengthy time period.]

FE.1 and FE-.2

If any Required Action of Condition A, B, [C, D or E-ý] cannot be metwithin the associated Completion Time, the plant must be brought to aMODE in which the LCO does not apply. To achieve this status, the plantmust be brought to at least MODE 3 within 12 hours and MODE 4 within36 hours. The allowed Completion Times are reasonable, based onoperating experience, to perform the actions in an orderly manner andwithout challenging plant systems.

GF-.1

With all required monitors inoperable, no required automatic means ofmonitoring LEAKAGE are available, and immediate plant shutdown inaccordance with LCO 3.0.3 is required.

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BASES

SURVEILLANCE SR 3.4.6.1REQUIREMENTS.

This SR is for the performance of a CHANNEL CHECK of the requiredprimary containment atmospheric monitoring system. The check givesreasonable confidence that the channel is operating properly. TheFrequencyof 12 hours is based on instrument reliability and is reasonablefor detecting off normal conditions.

SR 3.4.6.2

This SR is for the performance of a CHANNEL FUNCTIONAL TEST ofthe required RCS leakage detection instrumentation. The test ensuresthat the monitors can perform their function in the desired manner. Thetest also verifies the alarm setpoint and relative accuracy of theinstrument string. A successful test of the required contact(s) of achannel relay may be performed by the verification of the change of stateof a single contact of the relay. This clarifies what is an acceptableCHANNEL FUNCTIONAL TEST of a relay. This is acceptable becauseall of the other required contacts of the relay are verified by otherTechnical Specifications and non-Technical Specifications tests at leastonce per refueling interval with applicable extensions. The Frequency of31 days considers instrument reliability, and operating experience hasshown it proper for detecting degradation.

SR 3.4.6.3

This SR is for the performance of a CHANNEL CALIBRATION of requiredleakage detection instrumentation channels. The calibration verifies theaccuracy of the instrument string, including the instruments located insidecontainment. The Frequency of [18] months is a typical refueling cycleand considers channel reliability. Operating experience has proven thisFrequency is acceptable.

REFERENCES 1. 10 CFR 50, AppendixA, GDC 30.


3. FSAR, S6ction [5.24.2.4.,

43. GEAP-5620, April 1968.

54 NUREG-75/067, October 1975.

65. FSAR, Section [5.2.7.5.2].

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6. FSAR, Section [5.2.7.2.1].

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LCO 3.4.7 The following RCS leakage detection instrumentation shall beOPERABLE:

a. Drywell floor drain sump monitoring system, [and]

b. One channel of either drywell atmospheric particulate oratmospheric gaseous monitoring system, [ and

[c. Drywell air cooler condensate flow rate monitoring system.]

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS


A. Drywell floor drain sump A.1 Restore drywell floor drain 30 daysmonitoring system sump monitoring system toinoperable. OPERABLE status.

B. Required drywell B.1 Analyze grab samples of Once per 12 hoursatmospheric monitoring drywell atmosphere.system inoperable.

AND

B.2 [Restore required drywell 30 days]atmospheric monitoringsystem to OPERABLEstatus.

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ACTIONS (continued)


C. [Drywell air cooler ---------------- NOTE ---------condensate flow rate Not applicable when the requiredmonitoring system drywell atmospheric monitoringinoperable, system is inoperable. -

C.1 Perform SR 3.4.7.1. Once per 8 hours I

-NOTE -------------- D. 1 Analyze grab samples of Once per 12 hoursOnly applicable when the the drywell atmosphere.drywell atmosphericgaseous monitoring system ANDis the only OPERABLEmonitor. D.2 Monitor RCS LEAKAGE by Once per 12 hours

administrative means.

D. Drywell floor drain sump ANDmonitoring systeminoperable. D.3.1 Restore drywell floor drain 7 days

sump monitoring system toAND OPERABLE status.

[Drywell air cooler ORcondensate flow ratemonitoring system [D.3.2 Restore drywell air cooler 7 days 1inoperable.] condensate flow rate

monitorin.q system toOPERABLE status.

ED.[ Required drywell ED.1 Restore required drywell 30 daysatmospheric monitoring atmospheric monitoringsystem inoperable, system to OPERABLE

status.AND

ORDrywell air coolercondensate flow rate E9.2 Restore drywell air cooler 30 days]monitoring system condensate flow rateinoperable, monitoring system to

OPERABLE status.

FE. Required Action and FE-.1 Be in MODE 3. 12 hours

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associated CompletionTime of Condition A, B, AND[C, Dor ED] not met.

FE-.2 Be in MODE 4. 36 hours

GF.AII required leakage GF.1 Enter LCO 3.0.3. Immediatelydetection systemsinoperable.


SURVEILLANCE FREQUENCY

SR 3.4.7.1 Perform CHANNEL CHECK of required drywell 12 hoursatmospheric monitoring system.

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BASES

BACKGROUND GDC 30 of 10 CFR 50, Appendix A (Ref. 1), requires means for detectingand, to the extent practical, identifying the location of the source of RCSLEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2) describesacceptable methods for selecting leakage detection systems.

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB)are required so that appropriate action can be taken before the integrity ofthe RCPB is impaired (Ref. 2). Leakage detection systems for the RCSare provided to alert the operators when leakage rates above normalbackground levels are detected and also to supply quantitative.measurement of rates. [In addition to meeting the OPERABILITYrequirements, the monitors are typically set to provide the most sensitiveresponse without causing an excessive number of spurious alarms.1 TheBases for LCO 3.4.5, "RCS Operational LEAKAGE," discuss the limits onRCS LEAKAGE rates.

Systems for separating the LEAKAGE of an identified source from anunidentified source are necessary to provide prompt and quantitativeinformation to the operators to permit them to take immediate correctiveaction.

LEAKAGE from the RCPB inside the drywell is detected by at least one oftwo or three independently monitored variables, such as sump levelchanges and drywell gaseous and particulate radioactivity levels. Theprimary means of quantifying LEAKAGE in the drywell is the drywell floordrain sump monitoring system.

The drywell floor drain sump monitoring system monitors the LEAKAGEcollected in the floor drain sump. This unidentified LEAKAGE consists ofLEAKAGE from control rod drives, valve flanges or packings, floor drains,the Closed Cooling Water System, and drywell air cooling unitcondensate drains, and any LEAKAGE not collected in the drywellequipment drain sump. The drywell floor drain sump has transmitters thatsupply level indications in the main control room.

The floor drain sump level indicators have switches that start and stop thesump pumps when required. A timer starts each time the sump ispumped down to the low level setpoint. If the sump fills to the high levelsetpoint before the timer ends, an alarm sounds in the control room,indicating a LEAKAGE rate into the sump in excess of a preset limit. Asecond timer starts when the sump pumps start on high level. Should thistimer run out before the sump level reaches the low level setpoint, analarm is sounded in the control room indicating a LEAKAGE rate into the

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sump in excess of a preset limit. A flow indicator in the discharge line ofthe drywell floor drain sump pumps provides flow indication in the controlroom.

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BASES


The drywell air monitoring systems continuously monitor the drywellatmosphere for airborne particulate and gaseous radioactivity. A suddenincrease of radioactivity, which may be attributed to RCPB steam orreactor water LEAKAGE, is annunciated in the control room.. The dPywellatmosphere particuWlate and gaseous radioactiVity monitoring systems arenot capable of quantifying leakage rates, but are s.. ns.itive enough to

indiateinceasd LAKAGE= rates of 4 gpmn within 1 hour. L~argorchanges in; LEAKAGE rates are GeaeHete In DroArIloInall v snorer t.;

[Condensate from four of the six drywell coolers is routed to the drywellfloor drain sump and is monitored by a flow transmitter that providesindication and alarms in the control room. This drywell air coolercondensate flow rate monitoring system serves as an added indicator, butnot quantifier, of RCS unidentified LEAKAGE.]

APPLICABLESAFETYANALYSES

A threat of significant compromise to the RCPB exists if the barriercontains a crack that is large enough to propagate rapidly. LEAKAGErate limits are set low enough to detect the LEAKAGE emitted from asingle crack in the RCPB (Refs. 34 and 45). Each of the leakagedetection systemsr, inside the drpnwell i6 desig~nd with the capability4,detecting LEAKAGE less than the erstablished LEAKAGE rate limits andproviding appropriate alarm of excess-g LEFAK4QGE in the control room.

A control room alarm allows the operators to evaluate the significance ofthe indicated LEAKAGE and, if necessary, shut down the reactor forfurther investigation and corrective action. The allowed LEAKAGE ratesare well below the rates predicted for critical crack sizes (Ref. 56).Therefore, these actions provide adequate response before a significantbreak in the RCPB can occur..


LCO This LCO requires instruments of diverse monitoring principles to beOPERABLE to provide confidence that small amounts of unidentifiedLEAKAGE are detected in time to allow actions to place the plant in asafe condition, when RCS LEAKAGE indicates possible RCPBdegradation.


The drywell floor drain sump monitoring system is required to quantify theunidentified LEAKAGE rate from the RCS. Thus, for the system to beconsidered OPERABLE, either the flow monitoring or the sump levelmonitoring portion of the system must be OPERABLE and capable of

BWR/6 STS B,3.4.7-3 Rev. 3.0, 03/31/04

TSTF-514, Rev. 2


determining the leakage rate. The identification of an increase inunidentified LEAKAGE will be delayed by the time required for theunidentified LEAKAGE to travel to the drywell floor drain sump and it maytake longer than one hour to detect a 1 qpm increase in unidentifiedLEAKAGE, depending on the origin and magnitude of the LEAKAGE.This sensitivity is acceptable for containment sump monitorOPERABILITY.

The reactor coolant contains radioactivity that, when released to thedrywell, can be detected by the gaseous or particulate drywellatmospheric radioactivity monitor. Only one of the two detectors isrequired to be OPERABLE. Radioactivity detection systems are includedfor monitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE, but have recognizedlimitations. Reactor coolant radioactivity levels will be low during initialreactor startup and for a few weeks thereafter, until activated corrosionproducts have been formed and fission products appear from fuelelement cladding contamination or cladding defects. If there are few fuelelement cladding defects and low levels of activation products, it may notbe possible for the gaseous or particulate drywell atmosphericradioactivity monitors to detect a 1 qpm increase within 1 hour duringnormal operation. However, the gaseous or particulate drywellatmospheric radioactivity monitor is OPERABLE when it is capable ofdetecting a 1 qpm increase in unidentified LEAKAGE within 1 hour givenan RCS activity equivalent to that assumed in the design calculations forthe monitors (Reference 6).

[An increase in humidity of the drywell atmosphere could indicate therelease of water vapor to the drywell. Drywell air cooler condensate flowrate is instrumented to detect when there is an increase above the normalvalue by 1 qpm. The time required to detect a 1 qpm increase above thenormal value varies based on environmental and system conditions andmay take longer than 1 hour. This sensitivity is acceptable forcontainment air cooler condensate flow rate monitor OPERABILITY.1

The LCO is satisfied when monitors of diverse measurement means areavailable. Thus, the drywell floor drain sump monitoring system, incombination with a gaseous or particulate drywell atmosphericradioactivity monitor [and a drywell air cooler condensate flow ratemonitoring systemi, provides an acceptable minimum.The drywel' floor drain SUMP monitoring system is required to quantify' theuWni•dnti•f I EAKAGEr from thA RCS Thus, for Fthe• y•tem t beconsid;re;d OPERABLE, ei ther the; flow mnitortDIng or the UmlermonitoFrig portion of the system mus6t be8 OPERABLE. The otherl

moni~torintg ystefms prrvid early a!arms to the• •orrs soloser

.-.-. --.-.......... m-yt)a - ...'11---1100 -0--t-O1I.g0

extent Of any correctiVe acrtion tha~t May be required. Oith the leakagedetection systems nprbe monitoring for LEAKA.GE in the RCPB3 isdeqFaded.

BWR/6 STS B 3.4.7-4 Rev. 3.0, 03/31/04BWR/6 STS .B3.4.7-4 Rev. 10, 03/31/04

TSTF-514, Rev. 2


BASES

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to beOPERABLE to support LCO 3.4.5. This Applicability is consistent withthat for LCO 3.4.5.

ACTIONS A..1

With the drywell floor drain sump monitoring system inoperable, no otherform of sampling can provide the equivalent information to quantifyleakage. However, the drywell atmospheric activity monitor [and thedrywell air cooler condensate flow rate monitor] will provide indications ofchanges in leakage.

With the drywell floor drain sump monitoring system inoperable, but withRCS unidentified and total LEAKAGE being determined every 8 hours(SR 3.4.5.1), operation may continue for 30 days. The 30 dayCompletion Time of Required Action A. 1 is acceptable, based onoperating experience, considering the multiple forms of leakage detectionthat are still available.

B.1 and B.2

With both gaseous and particulate drywell atmospheric monitoringchannels inoperable,. grab samples of the drywell atmosphere shall betaken and analyzed to provide periodic leakage information. [Provided asample is obtained and analyzed every 12 hours, the plant may beoperated for up to 30 days to allow restoration of at least one of therequired monitors.] [Provided a sample is obtained and analyzed every12 hours, the plant may continue operation since at least one other formof drywell leakage detection (i.e., air cooler condensate flow rate monitor)is available.]

The 12 hour interval provides periodic information that is adequate todetect LEAKAGE. The 30 day Completion Time for restorationrecognizes that at least one other form of leakage detection is available.

BWRI6 STS B 3.4.7-5 Rev. 3.0, 03/31/04BWR/6 STS B 3.4.7-5 Rev. 3.0, 03/31/04

TSTF-514, Rev. 2


BASES

ACTIONS (continued)

[C.1

With the required drywell air cooler condensate flow rate monitoringsystem inoperable, SR 3.4.7.1 is performed every 8 hours to. provideperiodic information of activity in the drywell at a more frequent intervalthan the routine Frequency of SR 3.4.7.1. The 8 hour interval providesperiodic information that is adequate to detect LEAKAGE and recognizesthat other forms of leakage detection are available. However, thisRequired Action is modified by a Note that allows this action to be notapplicable if the required drywell atmospheric monitoring system isinoperable. Consistent with SR 3.0.1, Surveillances are not required tobe performed on inoperable equipment.]

D.1, D.2, D.3.1, and D.3.2

With the drywell floor drain sump monitoring system [and the drywell aircooler condensate flow rate monitorinq systemi inoperable, the onlymeans of detecting LEAKAGE is the drywell atmospheric gaseousradiation monitor. A Note clarifies this applicability of the Condition. Thedrywell atmospheric gaseous radiation monitor typically cannot detect a 1qpm leak within one hour when RCS activity is low. In addition, thisconfiguration does not provide the required diverse means of leakagedetection. Indirect methods of monitoring RCS leakage must beimplemented. Grab samples of the drywell atmosphere must be takenand analyzed and monitoring of RCS leakage by administrative meansmust be performed every 12 hours to provide alternate periodicinformation.

Administrative means of monitoring RCS leakage include monitoring andtrending parameters that may indicate an increase in RCS leakage.There are diverse alternative mechanisms from which appropriateindicators may be selected based on plant conditions. It is not necessaryto utilize all of these methods, but a method or methods should beselected considering the current plant conditions and historical orexpected sources of unidentified leakage. The administrative methodsinclude, but are not limited to, primary containment and drywell pressure,temperature, and humidity, Component Cooling Water System outlettemperatures and makeup, Reactor Recirculation System pump sealpressure and temperature and motor cooler temperature indications,Drywell cooling fan outlet temperatures, Reactor Building Chilleramperage, Control Rod Drive System flange temperatures, and SafetyRelief Valves tailpipe temperature, flow, or pressure. These indications,coupled with the atmospheric grab samples, are sufficient to alert theoperating staff to an unexpected increase in unidentified LEAKAGE.


TSTF-514, Rev. 2


The 12 hour interval is sufficient to detect increasing RCS leakage. TheRequired Action provides 7 days to restore another RCS leakage monitorto OPERABLE status to regain the intended leakage detection diversity.The 7 day Completion Time ensures that the plant will not be operated ina degraded configuration for a lengthy time period.

[ED.1 and E9.2

With both the gaseous and particulate drywell atmospheric monitorchannels and the drywell air cooler condensate flow rate monitorinoperable, the only means of detecting LEAKAGE is the drywell floordrain sump monitor. This Condition does not provide the required diversemeans of leakage detection. The Required Action is to restore either ofthe inoperable monitors to OPERABLE status within 30 days to regain theintended leakage detection diversity. The 30 day Completion Timeensures that the plant will not be operated in a degraded configuration fora lengthy time period.]

FE.1 and FE=.2

If any Required Action of Condition A, B, [C,.D or-D E] cannot be metwithin the associated Completion Time, the plant must be brought to aMODE in which the LCO does not apply. To achieve this status, the plantmust be brought to at least MODE 3 within 12 hours and to MODE 4

-within 36 hours. The allowed Completion Times are reasonable, basedon operating experience, to reach the required plant conditions in anorderly manner and without challenging plant systems.

G,_.1

With all required monitors inoperable, no required automatic means ofmonitoring LEAKAGE are available, and immediate plant shutdown inaccordance with LCO 3.0.3 is required.


TSTF-514, Rev. 2


BASES


This SR requires the performance of a CHANNEL CHECK of the requireddrywell atmospheric monitoring system. The check gives reasonableconfidence that the channel is operating properly. The Frequency of12 hours is based on instrument reliability and is reasonable for detectingoff normal conditions.

SR 3.4.7.2

This SR requires the performance of a CHANNEL FUNCTIONAL TEST ofthe required RCS leakage detection instrumentation. The test ensuresthat the monitors can perform their function in the desired manner. Thetest also verifies the alarm setpoint and relative accuracy of theinstrument string. A successful test of the required contact(s) of achannel relay may be performed by the verification of the change of stateof a single contact of the relay. This clarifies what is an acceptableCHANNEL FUNCTIONAL TEST of a relay. This is acceptable becauseall of the other required contacts of the relay are verified by otherTechnical Specifications and non-Technical Specifications tests at leastonce per refueling interval with applicable extensions. The Frequency of31 days considers instrument reliability, and operating experience hasshown it proper for detecting degradation.

SR 3.4.7.3

This SR requires the performance of a CHANNEL CALIBRATION of therequired RCS leakage detection instrumentation channels. Thecalibration verifies the accuracy of the instrument string, including theinstruments located inside the drywell. The Frequency of [18] months is atypical refueling cycle and considers channel reliability. Operatingexperience has proven this Frequency is acceptable.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 30.

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant PressureBoundary Leakagqe Detection Systems," May 1973.

3. FSAR, Section [5.2.5.2].

34. GEAP-5620, April 1968.

45. NUREG-75/067, October 1975.

f56. FSAR, Section [5.2.5.5.3].

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TSTF-514, Rev. 2


6. FSAR, Section [5.2.5.21.

BWR/6 STS B 3.4.7-9 Rev. 3.0, 03/31/04

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