ML093340520
| ML093340520 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/02/2009 |
| From: | Geoffrey Miller Dominion, Dominion Resources Services |
| To: | Cotton K Plant Licensing Branch II |
| Cotton K, NRR/DLPM, 301-415-1438 | |
| References | |
| Download: ML093340520 (6) | |
Text
Cotton. Karen From:
Gary D Miller [gary.d.miller@dom.com]
Sent:
Monday, November 02, 2009 1:54 PM To:
Cotton, Karen
Subject:
Revised TS pages missing from LAs 266/265 - Deletion of MCR/ESGR Bottled Air TS Requirements Attachments:
img-Y021405-0001.pdf
- Karen, As noted during our earlier phone call this date, I reviewed License Amendments (LAs) 266/265, issued by the NRC on October 29,2009 for Surry Units 1 and 2, respectively, to delete the MCR/ESGR Bottled Air TS Requirements. During my review, I noticed that the LAs do not include revised TS pages TS 3.21-2,3.21-3,4.1-5, 4.1-9c (TS Table 4.1-2A) and 6.4 14 that were included in Dominion's October 8,2009 LAR as marked-up and typed TS pages in Attachments 2 and 3, respectively. In addition, the page included in the NRC's LA transmittal letter that provides the TS page replacement directions does not include these pages either. Also, neither the NRC's cover letter nor the attached Safety Evaluation Report mention the supporting changes to the TS 3.21 and 4.1 Basis sections. (This may be due to their being Basis changes as opposed to actual TS changes.)
The TS pages missing from the October 29, 2009 License Amendments are attached. Please advise regarding how/when this issue can be corrected.
Thanks.
Gary D. Miller, P.E.
Nuclear Licensing and Operations Support Dominion Resources Services, Inc.
(804) 273-2771 or tie-line 8-730-2771 fax (804) 273-3715 garv.d.miller@dom.com CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
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c TS 3.21-2 BASES BACKGROUND - The MCRlESGR Emergency Ventilation System (EVS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.
The MCRIESGR EVS consists of four full capacity trains that supply filtered air to the MCRIESGR envelope and a MCRIESGR envelope boundary that limits the inleakage of unfiltered air. Each MCRJESGR EVS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves, dampers, doors, barriers, and instrumentation also fonn part of the system. One EVS train is capable of performing the safety function of providing outside filtered air for pressurization. Two independently powered EVS trains are required for independence and redundancy.
The MCRlESGR envelope is the area within the confines of the MCRlESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCRJESGR envelope is protected during normal operation, natural events, and accident conditions. The MCR/ESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCRlESGR envelope. The OPERABILITY of the MCRlESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCRlESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to MCRlESGR envelope occupants. The MCRJESGR envelope and its boundary are defined in the MCRlESGR Envelope Habitability Program (fS 6.4.R).
Upon receipt of the actuating signal(s), normal air supply to and exhaust from the MCRJESGR envelope is isolated. l\\vo dampers in series in both the MCRlESGR envelope supply and exhaust ducts close to isolate the MCRlESGR envelope. Approximately 60 minutes after the isolation of the MCRlESGR envelope, the MCRJESGR EVS is manually actuated. Each MCRJESGR EVS train provides filtered air from the Turbine Building to the MCRlESGR envelope through HEPA filters and charcoal adsorbers. Prefilters remove any large particles in the air to prevent excessive loading ofthe HEPA filters and charcoal adsorbers.
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Amendment Nos.
TS 3.21-3 Pressurization of the MCRJESGR envelope, although not required by the accident analyses, limits infiltration of unfiltered air from the surrounding areas adjacent to the MCRlESGR envelope.
A single train of the MCRlESGR EVS will pressurize the MCRJESGR envelope to about 0.05 inches water gauge relative to external areas adjacent to the MCRlESGR envelope boundary.
The MCRlESGR EVS operation in maintaining the MCRJESGR envelope habitable is discussed in the UFSAR, Section 9.13 (Ref. 3).
Redundant MCRJESGR EVS supply trains provide pressurization and filtration should one train fail to start or should an excessive pressure drop develop across the operating filter train. Isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The MCRlESGR EVS is designed in accordance with Seismic Category I requirements.
The MCRJESGR EVS is designed to maintain a habitable environment in the MCRJESGR envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).
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APPLICABLE SAFETY ANALYSES - The MCR/ESGR EVS components are arranged in redundant, safety related ventilation trains. The MCRlESGR EVS provides airborne radiological protection for the MCRlESGR envelope occupants, as demonstrated by the MCRlESGR envelope occupant dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 14 (Ref. 4).
The MCRIESGR EVS provides protection from smoke and hazardous chemicals to the MCRlESGR envelope occupants. An evaluation of hazardous chemical releases demonstrates that the toxicity limits for chemicals are not exceeded in the MCRlESGR envelope following a hazardous chemical release (Refs. 1 and 5) or that ample time is available for MCR/ESGR envelope occupants to isolate the MCRfESGR envelope. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the MCRJESGR envelope occupants to control the reactor either from the MCR or from the remote shutdown panel (Ref. 2).
The worst case single active failure of a component of the MCRJESGR EVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.
The MCRlESGR EVS satisfies Criterion 3 of 10 CPR 50.36(c)(2)(ii).
LIMITING CONDITIONS FOR OPERATION (LCO) - Two independent and redundant MCRlESGR EVS trains are required to be OPERABLE to ensure that at least one is available to pressurize and to provide filtered air to the MCRJESGR envelope assuming a single active failure disables one of the two required trains. Due to electrical power considerations, one train must be from the other unit. Total system failure, such as from a loss of both ventilation trains or from an inoperable MCRJESGR envelope boundary, could result in exceeding a dose of 5 rem TEDE to the MCRlESGR envelope occupants in the event of a large radioactive release.
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Amendment Nos.
TS 4.1-5 The refueling water storage tank is sampled weekly for CI-andlor F contaminations. Weekly sampling is adequate to detect any inleakage of contaminated water.
Main Control RoomlEmergency Switchgear Room (MCRfESGR) Envelope Isolation Actuation Instrumentation The MCRlESGR Envelope Isolation Actuation function provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity. A functional check of the Manual Actuation function is performed every 18 months. The test frequency is based on the known reliability of the function and the redundancy available and has been shown to be acceptable through operating experience. The Surveillance Requirement will ensure that the two trains of the MCRlESGR envelope isolation dampers close upon manual actuation of the MCRlESGR Envelope Isolation Actuation Instrumentation and that the supply and exhaust fans in the normal ventilation system for the MCRJESGR envelope shut down, as well as adjacent area ventilation fans.
Automatic actuation of the MCR/ESGR Envelope Isolation Actuation Instrumentation is confirmed as part of the Logic Channel Testing for the Safety Injection system.
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Pressurizer PORV, PORV Block Valve, and PORV Backup Air Supply The safety-related, seismic PORV backup air supply is relied upon for two functions - mitigation of a design basis steam generator tube rupture accident and low temperature overpressure protection (LTOP) of the reactor vessel during startup and shutdown. The surveillance criteria are based upon the more limiting requirements for the backup air supply (i.e. more PORV cycles potentially required to perform the mitigation function), which are associated with the LTOP function.
The PORV backup air supply system is provided with a calibrated alarm for low air pressure. The alarm is located in the control room. Failures such as regulator drift and air leaks which result in low pressure can be easily recognized by alarm or annunciator action. A periodic quarterly verification of air pressure against the surveillance limit supplements this type of built-in surveillance. Based on experience in operation, the minimum checking frequencies set forth are deemed adequate.
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Amendment Nos.
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TABLE 4.1-2A (CONTINUED)
MINIMUM FREQUENCY FOR EQUIPMENT reSTS DESCRIPTION 14a. Service Water System Valves in Line Supplying Recirculation Spray Heat Exchangers
- b. Service Water System Valves Isolating Flow to Non-essential loads on Intake Canal Low Level Isolation
- 15. MCRJESGR Envelope Isolation Actuation Instrumentation - Manual
- 16. Reactor Vessel Overpressure Mitigating System (except backup air supply)
- 17. Reactor Vessel Overpressure Mitigating System Backup Air Supply
- 18. Power-Operated Relief Valve Control System
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TEST Functional Functional Functional Functional & Setpoint CHANNEL CALIBRATION Setpoint Functional, excluding valve actuation CHANNEL CALIBRATION FREQUENCY Once per 18 months Once per 18 months Once per 18 months Prior to decreasing RCS temperature below 350°F and monthly while the RCS is <
350 0 P and the Reactor Vessel Head is bolted Once per 18 months Once per 18 months Monthly Once per 18 months FSAR SECTION REFERENCE 9.9 9.9 9.13 4.3 4.3 4.3 (j
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c TS 6.4-14 R. Main Control RoomlEmergency Switchgear Room (MCRJESGR) Envelope Habitability Program A Main Control RoomlEmergency Switchgear Room (MCRJESGR) Envelope Habitability Program shall be established and implemented to ensure that MCRlESGR envelope habitability is maintained such that, with an OPERABLE MCRJESGR Emergency Ventilation System (EVS), MCRlESGR envelope occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to pennit access and occupancy of the MCRlESGR envelope under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:
- 1. The definition of the MCRlESGR envelope and the MCRJESGR envelope boundary.
- 2. Requirements for maintaining the MCRlESGR envelope boundary in its design condition including configuration control and preventive maintenance.
- 3. Requirements for (a) determining the unfiltered air inleakage past the MCRlESGR envelope boundary into the MCRJESGR envelope in accordance with the testing
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methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (b) assessing MCRJESGR envelope habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.
The following is an exception to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:
- 2.C.l Licensing Bases - Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR. The exceptions to the Regulatory Guides (RGs) referenced in RG 1.196 (Le., RG 1.52, RG 1.78 and RG 1.183), which were considered in completing the vulnerability assessments, are documented in the UFSAR/current licensing basis. Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.
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Amendment Nos.