Text

NRR E-mail Capture - FW: Clinton Power Station Question Related to EGM 11-003, Revision 1
	ML13158A002
Person / Time
Site:	Clinton
Issue date:	05/31/2013
From:	Mathews M; Exelon Corp
To:	Blake Purnell; Plant Licensing Branch III
References
	Download: ML13158A002 (35)
	v • d • e

1 NRR-PMDAPEm Resource From:

Mitchel.Mathews@exeloncorp.com Sent:

Friday, May 31, 2013 11:35 AM To:

Purnell, Blake Cc:

James.Peterson@exeloncorp.com; patrick.simpson@exeloncorp.com; ThomasJames.Griffith@exeloncorp.com

Subject:

FW: Clinton Power Station Question Related to EGM 11-003, Revision 1 Attachments:

CPS TS 3.6.1.3 and TS B 3.6.1.3 9-6-12.pdf; Clinton Containment Building Ventilation and Drywell Purge System Training AAA BIG NOTES.pdf

Blake, The Clinton Power Station primary containment isolation valves that are also considered secondary containment bypass leakage isolation valves that we discussed during our telephone conversation are: 1VR001A, 1VR001B, 1VQ004A, and 1VQ004B. The training diagram showing these 36 damper-type valves has been attached for your information. As we discussed, these valves provide a flowpath to and from the refueling floor, providing for ALARA and air quality and safety considerations for personnel working on the refueling floor during the outage.

The overall scope of CPS outage work will render these valves inoperable and failed closed. The Applicability of Clinton Power Station (CPS) TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), is unique in that these valves are required to be operable during operations with the potential to drain the reactor vessel (OPDRVs). CPS outage plans currently contain OPDRV activities coincident with the time these valves are inoperable. In order to address ALARA and personnel safety issues discussed above, CPS would like to discuss the potential to allow discretion for these valves to be blocked open with air-operated gagging devices during OPDRV activities. Removal of the gagging devices is a simple activity that will allow the valves to fail closed and meet their safety function, if required. Specifically, this would require discretion to violate the requirements of TS 3.6.1.3, Required Actions A.1 and G.1 for these valves only.

Exelon believes that these actions are consistent with the intent of EGM 11-003, Revision 1 enforcement discretion Criterion 4e pertaining to closing secondary containment access doors and secondary containment equipment hatches before reactor pressure vessel (RPV) level reaches the top of the RPV flange. These valves can be closed with significant margin to the time RPV level would reach the level of the flange in any OPDRV scenario described by EGM 11-003.

Please call me with any questions or concerns.

Regards, Mitch Mitchel Mathews Sr. Regulatory Engineer Corporate Licensing 4300 Winfield Road - 4th Floor Warrenville, IL 60555 Office: 630-657-2819 l Pager: 630-603-0016 l Fax: 630-657-4327 Mitchel.Mathews@exeloncorp.com

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Subject:

FW: Clinton Power Station Question Related to EGM 11-003, Revision 1 Sent Date:

5/31/2013 11:34:34 AM Received Date:

5/31/2013 11:34:52 AM From:

Mitchel.Mathews@exeloncorp.com Created By:

Mitchel.Mathews@exeloncorp.com Recipients:

"James.Peterson@exeloncorp.com" <James.Peterson@exeloncorp.com>

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cccmsxch19.energy.power.corp Files Size Date & Time MESSAGE 2326 5/31/2013 11:34:52 AM CPS TS 3.6.1.3 and TS B 3.6.1.3 9-6-12.pdf 87404 Clinton Containment Building Ventilation and Drywell Purge System Training AAA BIG NOTES.pdf 269770 Options Priority:

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PCIVs 3.6.1.3 CLINTON 3.6-9 Amendment No. 158 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, MODES 4 and 5 for RHR Shutdown Cooling System suction from the reactor vessel isolation valves when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation," Function 5.c.

NOTE------------------------------

The following Applicabilities apply only to secondary containment bypass leakage isolation valves.

During movement of recently irradiated fuel assemblies in the primary or secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS

NOTES------------------------------------

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria in MODES 1, 2, and 3.

5. Not applicable for the Inclined Fuel Transfer System (IFTS) penetration when the associated primary containment blind flange is removed, provided that the fuel building fuel transfer pool water is maintained el. 753 ft., the steam dryer pool to reactor cavity pool gate is installed with the seal inflated and a backup air supply provided, the total time the flange is open does not exceed 40 days per operating cycle, and the IFTS transfer tube drain valve(s) remain(s) closed, except that the IFTS tube drain valve(s) may be opened under administrative controls.

(continued)

The following Applicabilities apply only to secondary containment bypass leakage isolation valves.

During operations with a potential for draining the reactor vessel (OPDRVs).

PCIVs 3.6.1.3 CLINTON 3.6-10 Amendment No. 95 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more penetration flow paths with one PCIV inoperable, except due to leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for main steam line and excess flow check valves (EFCVs)

AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam line AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for EFCVs AND (continued)

One or more penetration flow paths with one PCIV inoperable, except due to leakage not within limit.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

PCIVs 3.6.1.3 CLINTON 3.6-11 Amendment No. 95 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2

NOTE---------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

Once per 31 days for isolation devices outside primary containment, drywell, and steam tunnel AND Prior to entering MODE 2 or 3 from MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment, drywell, or steam tunnel (continued)

PCIVs 3.6.1.3 CLINTON 3.6-12 Amendment No. 95 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

One or more penetration flow paths with two PCIVs inoperable, except due to leakage not within limit.

B.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C.

One or more penetration flow paths with leakage rate not within limit, except for purge valve leakage.

C.1 Restore leakage rate to within limit.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (continued)

PCIVs 3.6.1.3 CLINTON 3.6-13 Amendment No. 95 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more penetration flow paths with one or more primary containment purge valves not within purge valve leakage limits.

D.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months D.2

NOTE--------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

AND Once per 31 days for isolation devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4 if not performed within the previous 92 days for isolation devices inside primary containment (continued)

PCIVs 3.6.1.3 CLINTON 3.6-14 Amendment No. 147 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.3 Perform SR 3.6.1.3.5 for the resilient seal purge valves closed to comply with Required Action D.1.

Once per 92 days E.

Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours F.

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during movement of recently irradiated fuel assemblies in the primary or secondary containment.

F.1

NOTE---------

LCO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in primary and secondary containment.

Immediately G.

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during MODE 4 or 5 or during OPDRVs.

G.1 Initiate action to suspend OPDRVs.

OR G.2 Initiate action to restore valve(s) to OPERABLE status.

Immediately Immediately (continued)

Required Action and associated Completion Time of Condition A, or D not met B, C, for PCIV(s) required to be OPERABLE during MODE 4 or 5 or during OPDRVs.

Initiate action to suspend OPDRVs.

Immediately

PCIVs 3.6.1.3 CLINTON 3.6-15 Amendment No. 192 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 -------------------NOTES-----------------

1. Only required to be met in MODES 1, 2, and 3.

2. Not required to be met when the 36 inch primary containment purge valves are open for pressure control, ALARA or air quality considerations for personnel entry. Also not required to be met during Surveillances or special testing on the purge system that requires the valves to be open. The 36 inch primary containment purge lines shall not be opened with a 12 inch primary containment purge line open nor with a drywell vent and purge supply or exhaust line open.

Verify each 36 inch primary containment purge valve is closed.

In accordance with the Surveillance Frequency Control program (continued)

PCIVs 3.6.1.3 CLINTON 3.6-16 Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.2 -----------------NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual valve and blind flange that is located outside primary containment, drywell, and steam tunnel and is required to be closed during accident conditions is closed.

In accordance with the Surveillance Frequency Control program (continued)

PCIVs 3.6.1.3 CLINTON 3.6-17 Amendment No. 158 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.3 ------------------NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual valve and blind flange that is located inside primary containment, drywell, or steam tunnel and is required to be closed during accident conditions is closed.

Prior to entering MODE 2 or 3 from MODE 4, if not performed within the previous 92 days (continued)

PCIVs 3.6.1.3 CLINTON 3.6-18 Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.4 Verify the isolation time of each power operated and each automatic PCIV, except MSIVs, is within limits.

In accordance with the Inservice Testing Program SR 3.6.1.3.5 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Perform leakage rate testing for each primary containment purge valve with resilient seals.

Once within 92 days after opening the valve AND In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 seconds and 5 seconds.

In accordance with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control program (continued)

PCIVs 3.6.1.3 CLINTON 3.6-19 Amendment No. 173 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.8 ------------------NOTE------------------

1.

Leakage through penetrations 1MC-101 and 1MC-102 is excluded.

2.

Only required to be met in MODES 1, 2, and 3.

Verify the combined leakage rate for all secondary containment bypass leakage paths is 0.08 La when pressurized to

Pa.

In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.9 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Verify the leakage rate through each MSIV leakage path is 100 scfh when tested at

Pa and the combined leakage rate for all MSIV leakage paths is 200 scfh when tested at Pa.

In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.10 ------------------NOTE------------------

Only required to be met in MODES 1, 2, and 3.

Verify combined leakage rate through hydrostatically tested lines that penetrated the primary containment is within limits.

In accordance with the Primary Containment Leakage Rate Testing Program (continued)

PCIVs 3.6.1.3 CLINTON 3.6-19a Amendment No. 192 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.11 ----------------NOTE--------------------

Only required to be met in MODES 1, 2, and 3.

Verify that the combined leakage rate for both primary containment feedwater penetrations is 2 gpm when pressurized to 1.1 Pa.

In accordance with the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.12 Verify each instrumentation line excess flow check primary containment isolation valve actuates within the required range.

In accordance with the Surveillance Frequency Control program

CLINTON 3.6-19b Amendment No. 107 This page intentionally left blank.

PCIVs B 3.6.1.3 CLINTON B 3.6-15 Revision No. 1-1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

BASES BACKGROUND The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs) to within limits. Primary containment isolation within the time limits specified for those PCIVs designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.

The OPERABILITY requirements for PCIVs help ensure that an adequate primary containment boundary is maintained during and after an accident by minimizing potential paths to the environment. Therefore, the OPERABILITY requirements provide assurance that the primary containment function assumed in the safety analysis will be maintained.

Typically two isolation barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or in leakage that exceeds limits assumed in the safety analysis. One of these barriers may be other than a PCIV, such as a closed system, while other penetrations may be designed with only one barrier such as a welded closed spare penetration. The isolation devices addressed by this LCO consist of either passive devices or active (automatic) devices. Manual valves, de-activated automatic valves, secured in their closed position, check valves with flow through the valve secured, and blind flanges are considered passive devices. Check valves and automatic valves, designed to close without operator action following an accident, are considered active devices.

The 12-inch supply (1VR006A and 1VR006B), 12-inch exhaust (1VR007A and 1VR007B), 36-inch supply (1VR001A and 1VR001B),

and 36-inch exhaust (1VQ004A and 1VQ004B) primary containment purge valves are PCIVs that are qualified for use during all operational conditions. The 36-inch primary containment purge valves are normally maintained closed in MODES 1, 2, and 3 to ensure leak tightness. The 36-inch purge valves must be closed when not being used for pressure control, ALARA, air quality considerations for personnel entry, or Surveillances or special testing on the purge system that require valves to be open to ensure that primary (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-16 Revision No. 1-1 BACKGROUND containment boundary assumed in the safety analysis will be (continued) maintained.

APPLICABLE The PCIVs LCO was derived from the assumptions related SAFETY ANALYSES to minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during major accidents. As part of the primary containment boundary, PCIV OPERABILITY supports leak tightness of primary containment. Therefore, the safety analysis of any event requiring isolation of primary containment is applicable to this LCO.

The DBAs that result in a release of radioactive material for which the consequences are mitigated by PCIVs, are a loss of coolant accident (LOCA), a main steam line break (MSLB), and a fuel handling accident (Refs. 1, 2, 3, and 4).

In the analysis for each of these accidents, it is assumed that PCIVs are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through PCIVs are minimized. Of the events analyzed, the LOCA is the most limiting event due to radiological consequences.

It is assumed that the primary containment is isolated such that release of fission products to the environment is controlled.

PCIVs satisfy Criterion 3 of the NRC Policy Statement.

LCO PCIVs form a part of the primary containment boundary and some also form a part of the RCPB. The PCIV safety function is related to minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during a DBA.

The power operated isolation valves are required to have isolation times within limits. Additionally, power operated automatic valves are required to actuate on an automatic isolation signal.

The normally closed PCIVs are considered OPERABLE when, as applicable, manual valves are closed or open in accordance with appropriate administrative controls, automatic valves are de-activated and secured in their closed position, or blind flanges are in place. The valves covered by this LCO are listed with their associated stroke times, if (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-17 Revision No. 1-1 LCO applicable, in the USAR (Ref. 5). Purge valves with (continued) resilient seals, secondary containment bypass isolation valves, MSIVs, and hydrostatically tested valves must meet other leakage rate requirements. Other PCIV leakage rates are addressed by LCO 3.6.1.1, "Primary Containment," as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory, and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves are required to be OPERABLE, however, to prevent inadvertent reactor vessel draindown and release of radioactive material during a postulated fuel handling accident. These valves are those that isolate the Residual Heat Removal (RHR) Shutdown Cooling supply and return lines and those PCIVs in lines which bypass secondary containment.

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated individual at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-18 Revision No. 8-6 ACTIONS The ACTIONS are modified by Notes 3 and 4. These Notes (continued) ensure appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve, or when the primary containment leakage limits are exceeded). Pursuant to LCO 3.0.6, these ACTIONS are not required even when the associated LCO is not met.

Therefore, Notes 3 and 4 are added to require the proper actions to be taken.

A fifth note has been added to allow removal of the Inclined Fuel Transfer System (IFTS) blind flange when primary containment operability is required. This provides the option of operating the IFTS for testing, maintenance, or movement of new (non-irradiated) fuel to the upper containment pool when primary containment operability is required. Requiring the fuel building fuel transfer pool water to be el. 753 ft. ensures a sufficient depth of water over the highest point on the transfer tube outlet valve in the fuel building fuel transfer pool to prevent direct communication between the containment building atmosphere and the fuel building atmosphere via the inclined fuel transfer tube. Because excessive leakage of water from the upper containment pool through the open IFTS penetration would result in the inability to provide the required volume of water to the suppression pool in an upper pool dump, an administrative control was required to ensure the upper pool volume meets the design requirements. In addition to the dedicated individual stationed at the IFTS controls, the required administrative controls involved the installation of the Steam Dryer Pool to Reactor Cavity Pool gate with the seal inflated and a backup air supply provided. Since the IFTS transfer tube drain line does not have the same water level as the transfer tube, and the motor-operated drain valve remains open when the carriage is in the lower pool, administrative controls are required to ensure the drain line flow path is quickly isolated in the event of a LOCA.

In this instance, administrative controls of the IFTS transfer tube drain line isolation valve(s) include stationing a dedicated individual, who is in continuous communication with the control room, at the IFTS control panel in the fuel building. This individual will initiate closure of the IFTS transfer tube drain line motor-operated isolation valve (1F42-F003) and the IFTS transfer tube drain line manual isolation valve (1F42-F301) if a need for primary containment isolation is indicated. The pressure integrity of the IFTS transfer tube, the seal created by water depth of the fuel building transfer pool, and the administrative control of the drain line flow path create an acceptable barrier to prevent the post-accident containment building atmosphere from leaking into the fuel building.

The total time per operating cycle that the blind flange may be open in Modes 1, 2, and 3 without affecting plant risk levels is 40 days.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-19 Revision No. 8-6 ACTIONS A.1 and A.2 With one or more penetration flow paths with one PCIV inoperable except for inoperability due to leakage not within a limit specified in an SR to this LCO, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. For penetrations isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest one available to the primary containment. The Required Action must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam lines and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for instrument line excess flow check valves (EFCVs)). The specified time period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the time required to isolate the penetration and the relative importance of supporting primary containment OPERABILITY during MODES 1, 2, and 3.

For main steam lines, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed.

The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the main steam lines allows a period of time to restore the MSIVs to OPERABLE status given the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown. For EFCVs, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is allowed. The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for EFCVs allows a period of time to restore the EFCVs to OPERABLE status given the fact that these valves are associated with instrument lines which are of small diameter and thus represent less significant leakage paths.

For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path must be verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be isolated should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification that those devices outside primary containment, drywell, and steam tunnel and capable of being mispositioned are in the correct position. The Completion Time for this verification of "once per 31 days for isolation devices outside primary containment, drywell, and steam tunnel," is appropriate because the devices are operated under administrative controls and the probability of their misalignment is low.

For devices inside primary containment, drywell, or steam tunnel, the specified time period of "prior to entering MODE 2 or 3 from MODE 4, if not performed within the previous 92 days," is based on engineering judgment and is considered reasonable in view of the inaccessibility of the devices and the existence of other administrative controls ensuring that device misalignment is an unlikely (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-20 Revision No. 8-6 ACTIONS A.1 and A.2 (continued) possibility.

Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows them to be verified by use of administrative means.

Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment; once they have been verified to be in the proper position, is low.

B.1 With one or more penetration flow paths with two PCIVs inoperable, except due to leakage not within limits, either the inoperable PCIVs must be restored to OPERABLE status or the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1.

C.1 With the secondary containment bypass leakage rate, hydrostatic leakage rate, or MSIV leakage rate not within limit, the assumptions of the safety analysis may not be met. Therefore, the leakage must be restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolation penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration and the relative importance to the overall containment function.

D.1, D.2, and D.3 In the event one or more primary containment purge valves are not within the purge valve leakage limits, purge valve leakage must be restored to within limits or the affected penetration must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, and blind (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-21 Revision No. 8-6 ACTIONS D.1, D.2, and D.3 (continued) flange. If a purge valve with resilient seals is utilized to satisfy Required Action D.1, it must have been demonstrated to meet the leakage requirements of SR 3.6.1.3.5. The specified Completion Time is reasonable, considering that one primary containment purge valve remains closed (refer to the requirements of SR 3.6.1.3.1; if this requirement is not met, entry into Condition A and B, as appropriate, would also be required), so that a gross breach of primary containment does not exist.

In accordance with Required Action D.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that primary containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be isolated should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it involves verification that those isolation devices outside primary containment and potentially capable of being mispositioned are in the correct position. For the isolation devices inside primary containment, the time period specified as "prior to entering MODE 2 or 3, from MODE 4 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For a primary containment purge valve with a resilient seal that is isolated in accordance with Required Action D.1, SR 3.6.1.3.5 must be performed at least once every 92 days.

This provides assurance that degradation of the resilient seal is detected and confirms that the leakage rate of the primary containment purge valve does not increase during the time the penetration is isolated. The normal Frequency for SR 3.6.1.3.5 is as required by the Primary Containment Leakage Rate Testing Program. Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR more often. Therefore, a Frequency of once per 92 days was chosen and has been shown acceptable based on operating experience.

E.1 and E.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-22 Revision No. 7-3 ACTIONS E.1 and E.2 (continued)

Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1, G.1 and G.2 If any Required Action and associated Completion Time cannot be met, the plant must be placed in a condition in which the LCO does not apply. If applicable, movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) in the primary and secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe condition. Also, if applicable, action must be immediately initiated to suspend operations with a potential for draining the reactor vessel (OPDRVs) to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended. If suspending the OPDRVs would result in closing the residual heat removal (RHR) shutdown cooling isolation valves, an alternative Required Action is provided to immediately initiate action to restore the valves to OPERABLE status. This allows RHR to remain in service while actions are being taken to restore the valve.

The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR verifies that the 36-inch primary containment purge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-22a Revision No. 7-3 SURVEILLANCE SR 3.6.1.3.1 (continued)

REQUIREMENTS outside of the limits. If the open valve is known to have excessive leakage, Condition D applies.

The SR is also modified by a Note (Note 1) stating that primary containment purge valves are only required to be closed in MODES 1, 2, and 3. If a LOCA inside primary containment occurs in these MODES, the primary containment purge valves are capable of closing before the pressure pulse affects systems downstream of the purge valves and the release of radioactive material will not exceed limits prior to the purge valves closing. At times other than MODE 1, 2, or 3 when the purge valves are required to be capable of closing (e.g., during movement of recently irradiated fuel assemblies) pressurization concerns are not present and the purge valves are allowed to be open (automatic isolation (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-22b Revision No. 14-2 SURVEILLANCE SR 3.6.1.3.1 (continued)

REQUIREMENTS capability would be required by SR 3.6.1.3.4 and SR 3.6.1.3.7).

The SR is modified by a Note (Note 2) stating that the SR is not required to be met when the purge valves are open for the stated reasons. The Note states that the 36-inch valves may be opened for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances or special testing on the purge system that require the valves to be open (e.g., testing of containment and drywell ventilation radiation monitors), provided the 12-inch containment purge and the drywell vent and purge lines are isolated. These primary containment purge valves are capable of closing in the environment following a LOCA.

Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.2 This SR verifies that each primary containment isolation manual valve and blind flange that is located outside primary containment, drywell, and steam tunnel, and is required to be closed during accident conditions, is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the primary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those devices outside primary containment, drywell, and steam tunnel, and capable of being mispositioned, are in the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Two Notes are added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-23 Revision No. 8-6 SURVEILLANCE SR 3.6.1.3.2 (continued)

REQUIREMENTS these devices, once they have been verified to be in the proper position, is low. A second Note is included to clarify that PCIVs open under administrative controls are not required to meet the SR during the time the PCIVs are open.

SR 3.6.1.3.3 This SR verifies that each primary containment manual isolation valve and blind flange located inside primary containment, drywell, or steam tunnel, and required to be closed during accident conditions, is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits. For devices inside primary containment, drywell, and steam tunnel, the Frequency of "prior to entering MODE 2 or 3 from MODE 4, if not performed within the previous 92 days", is appropriate since these devices are operated under administrative controls and the probability of their misalignment is low.

Two Notes are added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1, 2, and 3. Therefore, the probability of misalignment of these devices, once they have been verified to be in their proper position, is low. A second Note is included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-24 Revision No. 8-6 SURVEILLANCE SR 3.6.1.3.4 REQUIREMENTS Verifying the isolation time of each power operated and each automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.6.

The isolation time test ensures that the valve will isolate (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-25 Revision No. 10-5 SURVEILLANCE SR 3.6.1.3.4 (continued)

REQUIREMENTS in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

With regard to isolation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 8).

SR 3.6.1.3.5 For primary containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of the Primary Containment Leakage Rate Testing Program is required to ensure OPERABILITY. The acceptance criterion for this test is 0.02 La for each penetration when pressurized to Pa, 9.0 psig. Since cycling these valves may introduce additional seal degradation (beyond that which occurs to a valve that has not been opened), this SR must be performed within 92 days after opening the valve. However, operating experience has demonstrated that if a valve with a resilient seal is not stroked during an operating cycle, significant increased leakage through the valve is not observed. Based on this observation, a normal Frequency in accordance with the Primary Containment Leakage Rate Testing Program was established.

The SR is modified by a Note stating that the primary containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3. If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times when the purge valves are required to be capable of closing (e.g., during handling of recently irradiated fuel),

pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 9).

Dose associated with leakage through the primary containment purge lines is considered to be in addition to that controlled as part of the primary containment leakage rate limit, L a, and the 0.08 La limit for the other secondary containment bypass leakage paths.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-26 Revision No. 14-2 SURVEILLANCE SR 3.6.1.3.6 REQUIREMENTS (continued)

Verifying that the full closure isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The full closure isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. The Frequency of this SR is in accordance with the Inservice Testing Program.

With regard to isolation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 10).

SR 3.6.1.3.7 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.6 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.8 This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of References 1, 2, and 3 are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway (continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-27 Revision No. 11-2 SURVEILLANCE SR 3.6.1.3.8 (continued)

REQUIREMENTS leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR.

The Frequency is consistent with the Primary Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. Secondary containment bypass leakage is considered part of La.

Note 1 states that primary containment purge penetrations 1MC-101 and 1MC-102 are excluded from this SR verifying the secondary containment bypass leakage. The leakage through these penetrations is measured by SR 3.6.1.3.5 and the consequences associated with this leakage are evaluated separately as part of the LOCA analysis. Therefore, the leakage through the primary containment purge penetrations is excluded from the total secondary containment bypass leakage as verified in this SR. A second Note is provided to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2 and 3. In the other conditions, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 9).

SR 3.6.1.3.9 The analyses in References 1, 2, and 3 are based on leakage that is less than the specified leakage rate. Combined leakage through all four main steamlines must be 200 scfh when tested at Pa (9.0 psig). In addition, the leakage rate through any single main steam line must be < 100 scfh when tested at Pa. The MSIV leakage rate must be verified to be in accordance with the assumptions of References 1, 2, and

3. A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2, and 3. In the other conditions, the Reactor Coolant System is not pressurized and primary containment leakage limits are not required. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-28 Revision No. 4-6 SURVEILLANCE SR 3.6.1.3.9 (continued)

REQUIREMENTS With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 11).

SR 3.6.1.3.10 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 4 are met. The combined leakage rates (of 1 gpm times the total number of PCIVs when tested at 1.1 Pa) must be demonstrated at the frequency of the leakage test requirements of the Primary Containment Leakage Rate Testing Program.

This SR is modified by a Note that states that these valves are only required to meet the combined leakage rate in MODES 1, 2, and 3 since this is when the Reactor Coolant System is pressurized and primary containment is required.

In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1, 2, and 3. However, specific leakage limits are not applicable in these other MODES or conditions.

With regard to leakage rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 12).

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-28a Revision No. 14-2 SURVEILLANCE SR 3.6.1.3.11 REQUIREMENTS (continued)

This SR ensures that the combined leakage rate of the primary containment feedwater penetrations is less than the specified leakage rate. The leakage rate is based on water as the test medium since these penetrations are designed to be sealed by the FWLCS. The 2 gpm leakage limit has been shown by testing and analysis to bound the condition following a DBA LOCA where, for a limited time, both air and water are postulated to leak through this pathway. The leakage rate of each primary containment feedwater penetration is assumed to be the maximum pathway leakage, i.e., the leakage through the worst of the two isolation valves [either 1B21-F032A(B) or 1B21-F065A(B)] in each penetration. This provides assurance that the assumptions in the radiological evaluations of References 1 and 2 are met (Ref. 15).

Dose associated with leakage (both air and water) through the primary containment feedwater penetrations is considered to be in addition to the dose associated with all other secondary containment bypass leakage paths.

The Frequency is in accordance with the Primary Containment Leakage Rate Testing Program.

A Note is added to this SR which states that the primary containment feedwater penetrations are only required to meet this leakage limit in Modes 1, 2, and 3. In other conditions, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.

SR 3.6.1.3.12 This SR requires a demonstration that each instrumentation line excess flow check valve (EFCV) which communicates to the reactor coolant pressure boundary (Ref. 16) is OPERABLE by verifying that the valve activates within the required flow range. For instrument lines connected to reactor coolant pressure boundary, the EFCVs serve as an additional flow restrictor to the orifices that are installed inside the drywell (Ref. 14). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

PCIVs B 3.6.1.3 BASES CLINTON B 3.6-28b Revision No. 7-8 SR 3.6.1.3.12 (continued)

The operating limit or process parameter value associated with this SR, as read from plant indication instrumentation, is considered nominal. Instrument indications that are considered nominal do not require compensation for instrument indication uncertainties (Ref. 13).

Instrument lines that connect to the containment atmosphere, such as those which measure drywell pressure, or monitor the containment atmosphere or suppression pool water level, are considered extensions of primary containment. A failure of one of these instrument lines during normal operation would not result in the closure of the associated EFCV, since normal operating containment pressure is not sufficient to operate the valve. Such EFCVs will only close with a downstream line break concurrent with a LOCA. Since these conditions are beyond the plant design basis, EFCV closure is not needed and containment atmospheric instrument line EFCVs need not be tested (Ref. 16).

REFERENCES 1.

USAR, Chapter 15.6.5.

2.

USAR, Section 15.6.4.

3.

USAR, Section 15.7.4.

4.

USAR, Section 6.2.

5.

USAR, Table 6.2-47.

6.

10 CFR 50, Appendix J, Option B.

7.

Regulatory Guide 1.11.

8.

Calculation IP-0-0059.

9.

Calculation IP-0-0056.

10.

Calculation IP-0-0028.

11.

Calculation IP-0-0063.

12.

Calculation IP-0-0064.

13.

Calculation IP-0-0065.

14.

Calculation IP-M-0506 15.

License Amendment 127 16.

NEDO 32977-A, Excess Flow Check Valve Testing Relaxation

VR/VQ-1:

CONTAINMENT VENTILATION AND DRYWELL PURGE System BIG Notes LP# : 85455 Procedure # : 3408.01, 4411.06 Ref Dwgs # : M05-1110, M05-1111, OS-1110, OS-1111, E02-0VQ99, E02-1VQ99, E02-0VR99, E02-1VR99

!! FOR TRAINING USE ONLY !!

REV 0 Date: 09/24/03 ITS / ORM / ODCM ITS : 3.3.6.2, 3.6.1.3, 3.6.1.4, 3.6.5.3, 3.6.5.4 ORM : 2.5.2, Attachment 3 and 4 ODCM : None System Purpose/

A.System Purpose 1.The Containment Ventilation and Drywell Purge System, VR/VQ, provides heating, ventilation, and air conditioning to the Primary Containment and Drywell areas for both normal and emergency conditions.

2.Containment Ventilation consists of two subsystems.

a.The Continuous Containment Purge (CCP) subsystem is normally used during reactor modes 1, 2, and 3 and may also be used in reactor modes 4 and 5.

b.The Containment Building Ventilation (CBV) subsystem may be used for large volume ventilation of the Containment and Drywell during outages in modes 4 or 5.

3.The Drywell Purge Filter Trains may be used with either CCP or CBV to minimize release to the environment.

B.Safety Design Bases 1.Containment Building Ventilation System a.The containment building ventilation system is used during plant refueling operations and cold shutdown. Its use during normal operation is limited to an as-needed basis within limitations specified in the Technical Specifications to control containment airborne radioactive concentrations. Therefore this system has no safety design bases except for the containment building penetration isolation valves.

2.Continuous Containment Purge System a.The continuous containment purge system is not required to function in any but the normal station operating conditions to limit airborne radioactivity and maintain proper pressure boundaries in the containment. Therefore, this system has no safety design bases except for the CB penetration isolation valves.

3.Drywell Purge System a.The drywell purge system is not required to function in any but the normal station operating condition and, therefore, has no safety bases except for the CB penetration isolation valves.

C.Power Generation Design Bases 1.Containment Building Ventilation System a.The containment building ventilation system includes fan-coil cooling units supplied with cooling water from the plant chilled water system and is designed to limit the maximum temperatures in generally accessible areas of the containment building to 104 F.

The potentially contaminated cubicles will be limited to a maximum of 122 F, with the exception of the steam tunnel which will be limited to a maximum of 142 F. The temperature maintained in each area conforms to the equipment ambient requirements in that area. The fan coil cooling units are to be used continuously.

2.Continuous Containment Purge System The continuous containment purge system is designed to prevent the spread of airborne contamination by maintaining the areas where contamination may originate, such as the radiation cubicles, at a negative pressure compared to the general areas. The system is sized so as to maintain the airborne radiation levels in containment general areas at or below thirty percent of the derived air concentration under the design basis conditions of operation.

3.Drywell Purge System a.Drywell purging for airborne activity control is not permissible during plant operating modes 1, 2 or 3 since drywell supply air penetration/isolation valves 1VQ01A and 1VQ01B must remain closed during normal power operation, startup, or hot shutdown conditions.

Design Bases a.

Components A.Continuous Containment Purge Supply Fans 1.Continuous Containment Purge Supply Fan, 1VR06CA or B, supplies fresh air from outside, through a filter, heating and cooling unit, to the ductwork to the general areas inside the Containment Building. This provides forced circulation of ventilation air through the supply ductwork.

a.Only one of the two fans operates at a time. Each fan has a capacity of 8,000 cfm.

b.The inlet train includes a filter, cooling coil and heater.

c.Plant Chill Water (WO) is supplied to the cooling coil.

d.The fans are located in the Diesel Generator Building on 762 elevation.

2. CCP Supply Fan will trip when any of the following conditions exist:

a.CCP Mode Switch in an Off (neutral) position.

b.CCP Low Flow at Supply Fan (1)Indication that something may be wrong with the fan or a damper or valve is closed.

c.CCP Cnmt Bldg Supply Isolation Valve 1VR006A or B closes.

(1)Prevents pressurizing a closed duct.

d.CCP Exhaust Fans 1VR07CA and B stopped.

(1)Prevents pressurizing the Containment.

(2)Recall that for CCP, the CCP Exhaust Fans run in both Filtered and Unfiltered modes.

e.CCP Mode Switch in Filter with no DW Purge Fan, 0VQ02CA or B, Running (1)Prevents pressurizing the Containment.

F.Overcurrent 3.An isolation signal to one of the Containment Isolation valves will trip the fan when the valve closes.

B.CCP Supply Air Secondary Cooling Coil 1.The CCP Supply Air Secondary Cooling Coil provides for additional cooling of incoming air. Plant Chilled Water supplies the cooling coil.

2.The CCP Supply Air Secondary Cooling Coil is located inside Primary Containment on the 782' level.

C.Continuous Containment Purge Exhaust Fans 1.Continuous Containment Purge Exhaust Fan functions to remove air from the rooms inside Containment through the exhaust ductwork. A suction may also be taken on the Drywell and Drywell Head.

a.The fans are located in the Diesel Generator Building on 762 elevation.

2.Only one of the two fans operates at a time. Each fan has a capacity of 8,000 cfm. Flow may go directly to the Common Station HVAC Stack, or to the A or B DWPFT for filtration before going to the Stack. In conjunction with the modulating CCP Pressure Control Damper, 1VR04Y, in the supply path of CCP, the operating fan also serves to maintain the Containment building at a negative pressure of -0.25" WC with respect to atmosphere.

3.The CCP Exhaust Fan Trips are similar to the Supply Fan Trips.

a.They are: 1)CCP Mode Switch in an Off (neutral) position.

2)CCP Low Flow at Exhaust Fan a)Indication that something is wrong with the fan or a damper is closed.

3)CCP Cnmt Bldg Exhaust Isolation Valve 1VR007A or B closes.

a)Prevent drawing on a closed duct.

4)CCP Supply Fans 1VR06CA and B stopped.

a)Prevents a high negative pressure in Containment.

5)Overcurrent D.Containment Building Vent Supply Fans 1.When the system is in operation, one Supply Fan runs with one Exhaust Fan to force large quantities of fresh air through the Containment or Drywell during refueling or shutdown operations.

a.Each fan has a capacity of 16,270 cfm.

b.The Fan Selector Switch is placed in Fan A or Fan B Fast. The slow speed for the fans has been disconnected from the switch so that it cannot be used.

c.The CBV inlet train on Control Building 825 elevation includes a filter, WO cooling coil, and electric heater.

2.CBV is normally not used in modes 1, 2, or 3 because of restrictions on the 36-inch purge valves. During these modes, the 36-inch purge valves may be opened for pressure control, ALARA, or personnel considerations only.

3.CBV Supply Fan Trips - CBV Supply Fan will trip on the following conditions:

a.CBV Low Flow at Supply Fan.

1)Indication that something may be wrong with the fan or a damper is closed.

b.CBV Cnmt Bldg Supply Isolation Valve 1VR001A or B fully closed.

1)Prevent overpressure in the ducts.

c. In Vent mode, CBV Exhaust Fans 1VR04CA and B stopped.

1)Prevent positive pressure in Containment.

d.In any Purge mode, none of the three Drywell Purge Exhaust Fans running.

E.Containment Building Vent Exhaust Fans 1.The Containment Building Vent Exhaust Fans function to draw large amounts of air from the exhaust ductwork and force the air directly to the Common Station HVAC Stack for elevated, but unfiltered, release.

a.The capacity of each fan is 16,270 cfm.

b.Only one of the two fans operates at a time.

c.The CBV Exhaust Fans run for CBV Containment Vent mode only, not for Purge mode.

d.The fans are located in the Control Building on the 719 elevation.

2.CBV Exhaust Fan will trip on the following conditions:

a.CBV Cnmt Bldg Exhaust /Purge Isolation Valve 1VQ004A or B not fully open.

1)Prevent the fan pulling on a closed duct.

b.Other CBV Exhaust Fan Damper 1VR08YB, or A, not fully closed.

c.CBV Low Flow at Exhaust Fan 1)The fan may not be intact or a damper may be closed.

d.Containment Ventilation System Mode Switch not in CONTAINMENT VENT e.No CBV Supply Fan 1VR03CA or B Running 1)Prevents a high negative pressure in Containment.

F.Drywell Purge Filter Trains 1.The Drywell Purge Filter Trains function to remove particulate and gaseous contamination from the exhaust air before elevated release to the environment. The adsorption of gaseous contamination minimizes release of radioactivity from the plant.

a.The filter trains are located in the Control Building on the 702 elevation.

2.The Trains work like those for Standby Gas Treatment, which are described in the VG lesson plan. The main difference is in the Low Flow Inlet Heater, and the Low Flow Exhaust Fan.

a.The Low Flow Inlet Heater is a separate small heater on the inlet from the low flow pipe, which is only energized for low flow operation to cooldown the charcoal beds.

b.On the C Train, Low Flow mode is also used for PASS Panel Purge.

c.The Low Flow Exhaust Fan provides 300 cfm for cooling operations or PASS Purge.

Components (cont)

G.Drywell Purge Exhaust Fans 1.The Drywell Purge Exhaust Fans are part of the Drywell Purge Filter Trains. The fans draw air through the Drywell Purge Filter Trains and exhaust to the Common Station HVAC Stack for elevated release.

a.The fan capacity is rated at 15,000 cfm.

b.A smaller Low Flow fan used to cool the charcoal bed was described above.

2.The Drywell Purge Exhaust Fans will trip for any of the following conditions:

a.Motor overload b.CBV Supply Fan 1VR03CA and B off >5 sec. in any CBV purge mode.

c.CCP Supply Fan 1VR06CA and B off >50 sec. in CCP FILTERED or UNFILTERED mode.

d.Low Flow across a DW Purge Exhaust Fan, with different setpoints for CCP and CBV operation.

e.CCP FILTERED mode with CCP Cnmt Bldg Exh/Purge Isolation Valves 1VR007A and B not full open f.CBV System switch is in MANUAL, AND CBV Mode Switch is not in a purge mode position, OR Cnmt Bldg Exhaust/Purge Isol Valves 1VQ004A and 1VQ004B are not full open.

g.Fire Protection Filter Train Deluge valve 0FP166A(B,C) not full closed h.Inlet temperature > 150°F, sensed at Fire Damper 0VQ10Y 3.The Drywell Purge Train Low Flow Fans will trip on any of the following:

a.CRVICS A Armed and Depressed b.High Drywell Pressure 1.68 psig c.Reactor Low Level 2.

H.Head Purge Flexible Hose 1.The Head Purge Flexible Hose, when connected, provides a flowpath between the Reactor Vessel Head Flange and the Drywell Head Area Exhaust Flange for purging inside the Reactor Vessel Head before the head is lifted off.

Purging reduces airborne contamination to the Refuel Floor during Reactor Head removal.

I.Containment Building Transfer Fan 1.The Containment Building Transfer Fan, 1VR12C, circulates air between the RT Valve Room on the 816' level in Containment and the Holding Pump cubicle below it to provide cooling for the Holding Pumps.

2.The Fan transfers 3200 cfm from the RT Valve Room down into the Holding Pump Cubicle on 803'. VR ducts supply and additional 950 cfm to the Holding Pump Cubicle, and exhaust 600 cfm to the VR exhaust. A flow of 3550 cfm returns through the opening between the two rooms back up into the RT Valve Room. The VR exhaust duct from the RT Valve room removes the extra 350 cfm.

3.This fan must be started or stopped as a separate part of the procedure at CCP Local Panel 1PL17J. The fan is run for both CBV and for CCP operation.

J.Pressure Control Modulating Dampers 1.Pressure control for Primary Containment is provided by either CBV or CCP, depending on which one is operating.

A Primary Containment to Outside Atmosphere p signal modulates a damper downstream of the supply fan of either CBV or CCP.

a.There are two Pressure Control Modulating Dampers, damper 1VR03Y on the CBV supply piping, and damper 1VR04Y on the CCP supply piping. See Figure 1. Note that for CCP, 1VR04Y is actually inside Containment, downstream of the Secondary Cooling Coil.

K.Instrumentation 1.Primary Containment to Outside Atmosphere p a.Four pressure transmitters sense Containment to outside atmosphere differential pressure. Transmitters A and B go to a high select relay, as do C and D, and the high output of each pair is then averaged to produce the final control signal. Readout of the average is provided in the Main Control Room on DCS Point 1VR BA201.

Readout of the average is also available on CBV Local Panel 1PL68JA on CB 825', and on CCP Local Panel 1PL17J on DG 762'. The same average signal provides the modulating control signal.

b.The Containment Building HVAC System is designed to maintain a slight negative pressure in Containment, at

-0.25 in WC, with respect to atmosphere, during normal operation.

c.This is accomplished by regulating the rate at which supply air enters Containment with a modulating supply damper. The differential pressure controller compares the average Containment to outside atmosphere differential pressure control signal to the selected setpoint and modulates the damper, increasing or decreasing supply air flow as needed. Which damper controls, CBV or CCP, is determined by which supply fan is running.

The two systems cannot operate simultaneously, but they share a common control loop.

d.The Technical Specification requirement of Primary Containment to Secondary Containment differential pressure being > -0.25 psid and < 0.25 psid is satisfied by controlling Primary Containment at -0.25 in WC with respect to outside; and Secondary Containment, using VF, at -0.7 in WC with respect to outside. This also satisfies the surveillance requirement of keeping Secondary Containment at 0.25 in vacuum WC with respect to outside.

2.Primary Containment to Secondary Containment p a.Technical Specifications are written in terms of Primary Containment to Secondary Containment differential pressure, and this is what is recorded on the Unit Attendant rounds, on the UNIT ATTENDANT SURVEILLANCE LOG DATA SHEET, CPS 9000.02D001. Primary to Secondary Containment Differential Pressure is recorded from local panels 0PL39JA and B on 719' CB against the wall outside the VG rooms. The readout is on indicating control relays 1PY-VG145 on 0PL39JA and 1PY-VG147 on 0PL39JB. These relays are labeled Control Pressure Damper 1VG01YA (B).

b.The indicating control relays also provide the 2.56 psid interlock which prevents VG Drywell/Containment purge above 2.56 psid.

c.The relays isolate the VR to VG inlet dampers, 1VG01YA and B, respectively, and the four 4 inch containment isolation bypass valves, 1VR002A and B and 1VQ006A and B, respectively. If the pressure exceeds 2.56 psid, a white light will come on above the SGTS Train DW Purge Isolation Damper 1VG01YA and B switches on P801 to indicate an isolation.

L.Containment Isolation Valves 1.There are three CRVICS Groups of isolation valves for VR/VQ. They are Groups 10, 16, and 9.

2.Containment and Reactor Vessel Isolation Control Actuation, whether manual, or from an automatic isolation signal, will isolate the CCP and CBV Containment isolation valves and trip off the fans in the system. The fans will trip either from the isolated position of the valves, or from low flow as the valves close.

3.Group 10, Containment HVAC Isolations a.The valves for Group 10 are:1VR001A and B,1VQ004A and B, 1VR006A and B, 1VR007A and B, 1VR035 and 1VR036, to Modulating Damper 1VR04Y, 1VR040 and 1VR041, to Secondary Cooler WO outlet valve, 1WO521.

4.Group 16, Drywell Ventilation Isolation Valves aThe valves for Group 16 are: 1VQ002, 1VQ005, 1VQ001A and B, 1VQ003.

5.Group 9, Containment Pressure a.The valves for Group 9 are: 1VR002A and B, 1VQ006A and B

DIVISIONAL CODES Y

B G

O BLK R

!! FOR TRAINING USE ONLY !!

Yellow Div 1 Div 2 Div 3 Div 4 Non-Divisional Fire Protection Blue Green Orange Black Red WO CBV SUPPLY FE CONTROL BUILDING DIESEL GEN. BUILDING FUEL BUILDING 3CA 3CB Regulates M

M FILTER FILTER HEATING HEATING COOLING COOLING 2YA 2YB DRYWELL FE COMMON STATION HVAC STACK 4CA 4CB 1VQ01Y CB 719' ROOF ROOF CONTROL BUILDING FUEL BUILDING DIESEL GEN. BUILDING CONTROL BUILDING FE RM IDNS RM RMs 1VR007B 1VR007A 1VR08YB 1VR08YA VW VT 1VR03Y 1VR01Y 825' 1VR0-1VR002A 1VR002B 1VR0-HI CBV UE

-0.25" H2O (DUCTS)

CONTAINMENT CONTAINMENT 1VR001 B

A (2)

VAC. BKRS.

M M

SGTS M

(4)

M PASS PANEL M

PREFILTER HEATER M

300 FE FE FILTERS DEMISTER HEPA CHARCOAL HEPA 16,270 M

TRAIN B TRAIN C 6YA 5YA M

M M

PRE-HEATER 2CA 1VQ03Y 1VQ02Y M

0VQ0 3CA 1VQ006A 1VQ010 1VQ006 B M

1VQ002 DUCTS ROOM 1VQ004B 1VQ004A 1VQ 003 1VQ 005 M

CB 702' WO FE 6CA 6CB CCP SUPPLY 8,000 SCFM DG 762' 0VQ24YA CCP EXHAUST 8,000 CFM CCP DG 762' 1VQ020 1VRO1O 1VR0-1VR006 04A 04B 1VR006B WO TE FE 1VR0-7CA 7CB 09A 09B 1VR006A 1VRO4Y DOME 1VR017Y 1VR018Y POOLS 1VR055Y POOLS 16270 scfm VQ001A VQ001B CCP CBV DRYWELL PURGE FILTER PATH

!! FOR TRAINING USE ONLY !!

VR/VQ-2:

CONTAINMENT VENTILATION AND DRYWELL PURGE System BIG Notes LP# : 85455 Procedure # : 3408.01, 4411.06 Ref Dwgs # : M05-1110, M05-1111, OS-1110, OS-1111, E02-0VQ99, E02-1VQ99, E02-0VR99, E02-1VR99 REV 0 Date: 09/24/03 ITS / ORM / ODCM ITS : 3.3.6.2, 3.6.1.3, 3.6.1.4, 3.6.5.3, 3.6.5.4 ORM : 2.5.2, Attachment 3 and 4 ODCM : None Interrelationships A.Support Systems 1.Fuel Building Ventilation (VF) a.Fuel Building Ventilation normally supplies Secondary Containment and is not directly connected to CBV or CCP. CB pressure is controlled relative to outside atmosphere pressure.

High Radiation or a LOCA signal which isolates CBV or CCP also shuts down VF and automatically starts VG to ventilate Secondary Containment with filtered release.

2.Standby Gas Treatment (VG) a.The functional interrelationships between VG and Containment Building Ventilation are as follows:

1)A 10 inch VGline is connected to the 36 inch Containment Ventilation and Drywell Purge Exhaust line. VG normally is a standby emergency system, ready to ventilate Secondary Containment, but it also has a backup Containment Purge Mode. Normally CCP would be used, but if CCP was tripped off for some reason, VG could be used. For the Containment Purge Mode of SGTS, the 4 inch CBV Supply Bypass Valves are opened to supply air from the Fuel Building atmosphere into the Containment. Note that the outboard bypass valve opens into the Containment atmosphere instead of returning to the 36 inch pipe. The return to the 36 inch pipe has been flanged shut. For the exhaust path, the 4 inch CBV Drywell Purge Valves on the 36 inch line are also opened, and a pipe from the 36 inch line goes to VG.

2)The 2.6 psig SGTS Containment High Pressure Interlock will isolate the two 4 inch CBV Supply Bypass Valves, 1VR002A/B, from the VFatmosphere, as well as the two 4 inch Containment Building Ventilation Drywell Purge Exhaust Bypass valves, 1VQ006A, B, around the 36 inch isolation valves. These valves are used by SGTS for SGTS Containment Purge Mode, as noted above. High Containment pressure of 2.6 psig is indicated by a white light on the VG panel. As mentioned above, these relays are also used for recording the Primary Containment to Secondary Containment differential pressure.

3)The auto initiation signals for VG, except for VFExhaust high radiation, will also isolate and trip off CBV or CCP. Note that this will leave the Containment Building without ventilation until the isolation signal clears and is reset.

3.Containment and Reactor Vessel Isolation Control (CRVICS) a.CRVICS will isolate VR/VQ in any mode if a Group 10, Containment Building HVAC Isolation, and Group 16, Drywell Ventilation signal occurs.

b.The purpose of the Automatic System Isolations are to prevent release of radioactivity to the environment.

4.Plant Chilled Water (WO) a.Plant Chilled Water (WO) provides cooling to the inlet air for both CCP and CBV, and provides cooling to the CCP supply Secondary Cooler inside the Containment as well.

5.Service and Instrument Air (SA/IA) a.SA/IA provides motive and control air for the air operated dampers and valves and pneumatically operated controls in the system. Most of the larger dampers and valves in the system are air operated.

6.Fire Protection (FP) a.FP provides water to the deluge spray nozzles in the charcoal bed in each of the three Drywell Purge Filter Trains. A motor operated valve in each FP inlet line may be remotely opened by the operator (only if a high-high temperature condition at 250°F exists) to flood the adsorbers if a fire occurs.

The isolation signals for Group 10 and Group 16 valves are as follows:

1)Containment Building Exhaust Radiation High or INOP, 100 mr/hr.

2)Containment Building Fuel Transfer Pool Vent Plenum Radiation High, 100 mr/hr 3)Containment CCP Exhaust Radiation High or INOP, 100 mr/hr 4)Drywell Pressure High, 1.68 psig 5)RPV Level Low, Level 2, -45.5 in.

NOTE: These signals also isolate VF and initiate VG.

The isolation signal for the Group 9 valves is:

1.Primary Containment to Secondary Containment p, 2.56 psid.

CLOSES : 1VR002A/B 1VR001 B

A 1VRO4Y 1VRO4Y 1VQ004B 1VQ004A Q

3 Q

6 B Q

3

ML13158A002

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