ML17254A694

Revised Proposed Tech Spec Changes,Adding New mini-purge Sys & Deleting Requirements for Old 48-inch Containment Purge Sys

ML17254A694
Person / Time
Site:	Ginna
Issue date:	12/23/1985
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17254A693	List: ML17254A692 ML17254A694
References
NUDOCS 8512310158
Download: ML17254A694 (19)

Text

TABLE 3.5-7 Radiation Accident Monitorin Instrumentation Minimum Channels Instrument ~Oerable Action

1. Containment Area (R-29 and R-30)

2. Noble Gas Effluent Monitor's Plant Vent (R-14)

A Main Steam Line (R-31) 111 B Main Steam Line (R-32)

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~ Containment Purge (R-12A) v ~ Air Ejector (R-15A)

Action Statements Action 1 - With the number of operable channels less than required by the Minimum Channels Operable requirements, either restore the inoperable channel(s) to operable status within 7 days of the event, or prepare and submit. a Special Report to the Commission within 30 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to operable status.

• only when the shutdown purge system flanges are removed.

8512310158 851223 PDR ADOCK 05000244 I

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3. 5-22 Proposed

3.6.3 Containment. Isolation Valves 3.6.3.1 With one or more of the isolation valve(s) specified in Table 3.6-1 inoperable, maintain at least one isolation valve operable in each affected penetration that is open and either:

a 0 Restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or

b. Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured in the isolation position, or 1I c Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual valve or blind flange, or

d. Be in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours.

Isolation valves are inopeable from a leakage standpoint if the leakage is greater than 50 Appendix J.

that allowed by 10 CFR 3.6.4 Combustible Gas Control 3.6.4.1 When the reactor is critical, at least two independent containment hydrogen monitors shall be operable. One of the monitors may be the Post Accident Sampling System.

3. 6.4.2 With only one hydrogen monitor operable, restore a second monitor to operable status within 30 days or be in at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.6.4.3 With no hydrogen monitors operable, restore at least one monitor to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be at least hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.6.5 Containment. Mini-Pur e Whenever the containment integrity is required, emphasis will be placed on limiting all purging and .

venting times to as low as achievable. The mini-purge isolation valves will remain closed to the maximum extent practicable but.may be open for pressure control, for AIARA, for respirable air quality consider-ations for-personnel entry, for surveillance tests that reguire the valve to be open or other safety related reasons.

3.6-2 Proposed

MAXIMUM MAXIMUM PENT. ISOLATION ISOLATION ISOLATION ISOLATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME (SEC) BOUNDARY TIME ="(SEC) 121 Nitrogen to PRT CV 528 NA MV 547(8) NA 121 Reactor Makeup water to PRT CV 529 NA AOV 508 60 121 Cont. Press. transmitter PT-945 (10) -PT 945 NA MV 1819A 121 Cont. Press. transmitter PT-946 (10) PT 946 NA MV 1819B NA 123 Reactor Coolant Drain Tank (RCDT) to GA AOV 1789 60 MV 1655(7) -

NA 124 Excess letdown supply and return AOV 745 60 NA to heat exchanger CV 743 NA NA 124 Post Accident air sample "C" fan MV 1569 NA MV 1571 NA MV 1572 NA MV 1574 NA 125 Component Cooling Mater (CW) from 1B RCP MOV 759B NA (12) NA 126 COW from lA RCP MOV 759A NA (12) NA 127 CCM to lA RCP CV '750A MOV 749A 60 128 CON to 1B .RCP CV 750B NA MOV 749B 60 0

e 129 RCDT 6 PRT- to Vent Header AOV 1787 60 AOV 1786 60 CV 1713 NA 130 CCM to reactor support cooling MOV 813 60 (19) NA 131 COW to reactor support cooling MOV 814 60 (19) NA 132 Mini-Purge exhaust AOV 7970 AOV 7971 140 RHR pump suction from "A" Hot leg MOV 701(20) NA (6) NA

MAXIMUM MAXIMUM PENT. ISOLATION .ISOLATION ISOLATION ISOLATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME "(SEC) BOUNDARY TIME "-(SEC) 141 RHR-Ijl pump suction from Sump B MOV 850A(13) NA MOV 851A(13) NA 142 RHR-g2 pump suction from Sump B MOV 850B(13) NA MOV 851B(13) NA 143 RCDT pump suction AOV 1721 60 AOV 1003A 60 AOV. 1003B 60 201 Reactor Compart. cooling Unit A 6 B MV 4757(16) NA NA MV 4636(16) NA 202 "B" Hydrogen recombiner (pilot 8 main) MV 1076B NA SOV IV-3B NA Normally Closed MV 1084B NA SOV IV-5B NA Normally Closed 203 Contain, Press. tr'ansmitter PT-947 8-948 PT 947 NA MV 1819C NA PT 948 NA MV 1819D NA 203 Post accident air sample to "B" fan MV 1563 NA MV 1565 NA MV 1566 NA MV 1568 NA 204 Shutdown Purge Supply Duct flange (22) NA AOV 5869 (22) 205 Hot leg loop sample AOV 966C 60 MV 956D(14) NA 0

a 206 Przr..liquid space sample AOV 966B 60 MV 956E(14) NA 206 "A" S/G sample AOV 5735 60 MV 5733(7) NA 207 Przr. Steam space sample AOV 966A 60 MV 956F NA 207 "B" S/G sample AOV 5736 60 MV 5734(7) NA 209 Reactor Compart. cooling Units A 8 B MV 4758(16) NA NA MV 4635(16) NA NA 210 Oxygen makeup to A 8 B recombiners MV 1080A NA SOV IV-.2A NA Normally Closed SOV IV-2B NA Normally Closed

I HAXIMUM MAXIMUM PENT. ISOLATION ISOLATION ISOLATION ISOLATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME -(SEC) BOUNDARY TIME " (SEC) 300 Shutdown Purge Exhaust Duct flange (22) NA AOV 5879 (22) 301 Aux. steam supply to containment MV 6151 NA MV 6165(15) NA 303 Aux. steam condensate return MV 6175 NA MV 6152(15) 304 "A" Hydrogen recombiner (pilot and main) MV 1084B NA SOV IV-5A NA Normallly Closed MV 1076A NA SOV IV-3A NA Normallly Clos o 305 Radiation Monitors R-,ll, R-12 6 R-10A AOV 1597 60 MV 1596 NA I

Auto Inlet Isol.

305 R-ll, R-12 6 R-10A Outlet AOV 1599 60 AOV 1598 60 305 Post Accident air sampler (containment) MV 1554 NA MV 1556 60 MV 1557 NA MV 1559 NA MV 1560 NA MV 1562 NA

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Q 307 Fire Service Water CV 9229 NA AOV 9227 (18) 308 Service Water to "A" fan cooler MV 4627(16) NA NA 0

m m309 Mini-Purge supply AOV '7478 AOV 7445 310 .Service Air to Contain. CV 7226 NA MV 7141 NA 310 Instrument Air to Contain. CV-5393 NA AOV 5392 60 311 Service Water from "B" fan cooler MV 4630(16) 312 Service Water to "D" fan cooler MV 4642(16) NA NA 313 Leakage test depressurization flange NA MOV 7444 NA Normally Closed

MAXIMUM MAXIMUM PENT. ISOLATION ISOLATION ISOLATION ISOLATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME "(SEC) BOUNDARY TIME (SEC) 315 Service Water from "C" fan cooler MV 4643(16) NA (ll) NA 316 Service Water to "B" fan cooler MV 4628(16) NA (11) 317 Leakage test supply flange NA MOV 7443 NA Normally Closed 318 Dead weight tester (decomissioned) welded shut NA welded shut NA 319 Service Water from "A" fan cooler MV 4629(16) NA NA 320 Service water to "C" fan cooler MV 4647(16) NA NA I

321 A S/G Blowdown AOV 5738 60 MV 5701(7) NA 322 B S/G Blowdown AOV 5737 60 MV 5702(7) NA 323 Service Water from "D" fan cooler MV 4644(16) NA NA 324 Demineralized water to Containment CV 8419 NA AOV 8418 332 Cont. Press. Trans. PT-944, 949 8 950 PT 944 NA MV 1819G NA PT 949 NA MV 1819F NA PT 950 NA MV 1819E NA 332 Ieakage test and hydrogen monitor MV 7448 NA cap NA instrumentation lines MV 7452 NA cap NA MV 7456 NA cap NA SOV 921 NA (21) NA SOV 922 NA (21) NA SOV 923 NA (21) NA SOV 924 NA (21) NA

(21) Acceptable isolation capability is provided for instrument lines by two isolation boundaries outside containment. One of the boundaries outside containment may be a Seismic Class 1 closed system which is subjected to Type C leak rate testing.

(22) The flanges at penetrations 204 and 300 can only be removed at cold or refueling shutdown. The flanges and associated double seals provide containment isolation and are a containment boundary for all modes of operation between cold shutdown and norrhal operation. During cold and refueling shutdown when the flanges are removed integrity is provided by the 48 inch valves.

3.6-11 Proposed

REFUELING

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Applies to operating limitations during refueling operations.

To ensure that no incident could occur during refueling operations that would affect public health and safety.

During refueling operations the following conditions shall be satisfied.

a ~ The equipment door, or a closure plate that restricts air flow from the containment, and at least one personnel door in the equipment. door or closure plate and in the personnel air lock shall be properly closed. In addition, all automatic containment isolation valves shall be operable or at least one valve in each line shall be locked closed. The 48 inch shutdown purge valves must also be operable or closed or the associated flange must. be installed.

b. Radiation levels in the containment shall be monitored continuously.

C. Core subcritical neutron flux shall be contin-uously monitored by at least two source range neutron monitors, each with continuous visual indication in the control room and one with audible indication in the containment and control room available whenever core geometry's being changed. When core geometry is not being changed at 3.8-1 Proposed

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shu down and depressurized untx repairs are effected and the local leakage meets the acceptance criterion.

c If it is determined that the leakage through a mini-purge supply and exhaust line is greater than 0..05 La an engineering evaluation shall be performed and plans for corrective action developed.

4.4.2.4 Test Fre enc a ~ Except as specified in b., c., and d. below, individual penetrations and containment isolation valves shall be tested during each reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than two years. In addition, the four mini-purge isolation valves shall be tested at six month intervals.*

b. The containment equipment hatch, fuel transfer tube, and shutdown purge system flanges shall be

'tested at, each refueling shutdown or after each use, if that be sooner.

• (This requirement is applicable for two years following installation of the mini-purge system).

4.4-7 Proposed

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c ~ The containment air locks shal be tested at intervals of no more than six months by pressurizing the space between the air lock doors. In addition, following opening of the air lock door during the interval, a test shall be performed by pressurizing between the dual seals of each door opened, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the opening, unless the reactor was in the cold shutdown condition at the time of the opening or has been subsequently brought to the cold shutdown condition. A test shall also be performed by pressurizing between the dual seals of each door within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of leaving the cold shutdown condition, unless the doors have not been open since the last test performed either by pressurizing the space between the air lock doors or by pressurizing between the dual door seals.

4.4.3 Recirculation Heat Removal S stems 4.4.3.1 Test a ~ The portion of the residual heat removal system that is outside the containment shall either be tested by use in normal operation or hydrostati-cally tested at 350 psig at the interval specified in 4.4.3.4.

b. Suction piping from containment sump B to the reactor coolant drain tank pump and the discharge piping from .the pumps to the residual heat removal system shall be hydrostatically tested at. no less that 100 psig at the interval specified in 4.4.3.4.

4.4-8 Proposed

Attachment B Containment purge and vent operations became a generic concern in 1978. Since that time containment purge and vent has been the subject of many letters between the Staff and Rochester Gas and Electric Corp. (RG&E). In Reference 1, the Staff transmitted to RG&E a Safety Evaluation Report (SER) which found RGE's interium commitments to be acceptable. The SER provides a good summary of the correspondance and the commitments made concerning this subject.

The existing purge and vent systems at Ginna consist of a 48 inch purge system and a 6 inch containment vent .(depressurization) system. The major issue concerning the purge system is the operability of the 48 inch purge valves during a design basis accident, loss of coolant accident (DBA-LOCA). Therefore, RG&E has committed to maintaining the 48 inch purge valves closed while the reactor is critical until information demonstrating operability is submitted.

In response to the Staff's request to limit purge/vent operations to safety-related needs RG&E committed to limiting vent. system operation to a total of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year.

To permanently resolve the purge and vent issue has decided to modify the 48 inch purge system so that it RG&E will only be used when the reactor is in cold or refueling shutdown, and install a mini-purge system which will allow limited purging of containment..

The technical specification changes presented in Attachment A are necessary to implement these modifications.

The following changes will be made to the 48 inch purge system:

The inboard 48 inch, butterfly-type containment isolation valves from both the supply and exhaust lines will be removed. Each valve will be replaced with a special blind-flange type closure utilizing double 0-ring seals to provide redundant containment isolation barriers. Test ports will be provided to permit peri-odic local leak rate testing of the double 0-ring seal. The

.blind flange closures will be securely bolted in place during reactor operation and will only be removed during plant shutdowns.

The existing outboard 48 inch, butterfly-type automatic containment isolation valves will remain in place to provide an isolation barrier during refueling operations.

Since the blank flanges have a double seal, .it will no longer be necessary to rely on the outer 48 inch valves for containment isolation during power operation. During cold or refueling shutdown, the flanges could be removed and the outer valves will be relied upon for refueling integrity. Since the 48 inch valves are no longer relied upon for containment integrity the mechanical stops on the valves will be removed. These stops were installed to reduce stresses in the valves resulting from closure during a DBA-LOCA. Since the valves are no longer subject to a DBA-LOCA there is no reason to continue restricting air flow in the 48 inch system during shutdown.

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A new mini-purge system will be installed to provide the capability to purge containment atmosphere on a limited basis during all modes of reactor operation. This 2000-cfm mini-purge system will consist. of a blower for supplying air to the containment. through existing 6 inch Integrated Leak Rate Test (ILRT) vent line penetra-tion 309. New 6 inch, air-operated, butterfly-type, inboard and outboard automatic containment isolation valves will be installed at penetration 309. Air will be exhausted through the existing 6 inch depressurization penetration 132 .and will be ducted into the Auxiliary Building ventilation system where it will be filtered and monitored prior to its release to the environment via the plant vent. The existing 6 inch valves at penetration 132 will be replaced with new 8 inch, air-operated, butterfly-type, inboard and outboard containment isolation valves. All four new containment isolation valves will be automatic and will be fully-qualified to close within 5 seconds from the time the isolation setpoint is reached against the maximum containment, pressures anticipated during a DBA-LOCA. The inboard ends of the mini-purge supply and exhaust lines will be equipped with 1/2-inch mesh debris screen's.

The radiation accident monitor R-12A (Containment Purge) monitors the 48 inch purge exhaust. Since the 48 inch purge will only be

'operable during cold and refueling shutdown, R-12A need only be operable during cold and refueling shutdown. Therefore, Table 3.5-7 was modified to be consistant with operation of the shutdown purge system.

In accordance, with 10 CFR 50.91, these changes to the Technical Specifications have been evaluated against three criteria to determine if the operation of the facility in accordance with proposed amendment would:

1. involve a significant increase in the probability or consequences of an accident previously evaluated; or

2. create the possibility of a new or different kind of accident from any accident previously evaluated; or

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

The modification does not involve an increase in the probability or consequences of an accident previously evaluated. Installing a mini-purge system and installing flanges on the 48 inch valves does not increase the probability of an accident because the flanges eliminate the effects of any malfunction of the 48 inch valves and the new mini-purge valves are small and inherently more reliable than the 48 inch valves. The consequences of any previously evaluated accident are .not increased by the modification because the flanges prevent any accident associated with the 48 inch system and clearly any accident associated with the mini-purge system is less limiting than an accident. associated with the 48 inch sytem.

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The modification does not create" the possibility of a new or different kind of accident. Replacing the 48 inch purge system with a mini-purge system basically decreases the size of the purge system and therefore does not create a new or different kind of accident.

The modification does not. significantly reduce the margin of safety because the consequences of any accident with the mini-purge system would be less severe than an accident associated with the 48 inch system.

As outlined above, Rochester Gas and Electric submits that the issues associated with this amendment request are outside the criteria of 10 CFR 50.91, and therefore, a no significant hazards finding is warranted.

Reference 1 NRC letter from D.M. Crutchfield to R.W. Kober, "Completion of Generic Issue On Containment Purge and Vent Operation" June 21, 1984.

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