ML20034C476

Application for Amends to Licenses DPR-39 & DPR-48,changing Tech Specs to Address Containment Spray Recirculation Phase Function,Per 890531 Enforcement Conference

ML20034C476
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/27/1990
From:	Chrzanowski R COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20034C475	List: ML20034C474 ML20034C476 ML20034C477 ML20034C740
References
NUDOCS 9005030368
Download: ML20034C476 (8)

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T April 27, 1990 Dr. Thomas E,.Murley, Director Office of Nuclear Reactor Regulation-U.S. Nuclear Regulatory Connaission Washington, DC 20555 Attn. Document Control Desk-l s

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Subject:

Zion Station Units 1 and 2 i

Application for Amendment to Facility Operating License DPR-39 and DPR-48 3

NRC Donket No.si 50-295 and 50-304 t

Dear Dr. Murley:

Conunonwealth Edison proposes to amend Appendix A, Technical Specifications for Facility Operating. Licenses DPR-39 and DPR-48 for the Zion Station, pursuant to 10 CFR 50.90.

This proposed Technical Specification change is based upon an evaluation that determined a specific Technical Specification should be written to address'the containment spray recirculation.

phase function.

On May 31,.1989, an Enforcement Conference was held at the NRC Region-III office regarding the inoperability of one train of the Unit 1~ Containment

~

Spray System due to the inoperability of 1MOV-CS-0049. The inoperability of this valve rendered one train of the Containment Spray System unable to function in the recirculation phase of operation, i

The conclusion of the Enforcement Conference was that operation with an inoperable train of containment spray resulted in a Severity Level IV' violation of the Zion Technical' Specifications.

i Zion Station has reviewed the Byron /Braidwood and Westinghouse Owners Group Standardized Technical Specifications for similar application. As a result, a new Limiting Condition for Operation (LCO) 3.6.2, titled L

" Containment Spray Recirculation Phase Systems: will be added to the-basis section of Specification 3.6, Containment Spray.. In addition, a paragraph l

will be added to the basis section of Specification 3.8, Emergency Core l

Cooling System (ECCS) to address.the functional requirements of.the system-

[

during the recirculation phase of operation.

The new LCO addressing Containment Spray Recirculation System operation and the new paragraph describing the functional requirements of the ECCS system during the recirculation phase of operation, will improve the overall safety of the plant by providing better operability decision making process regarding containment spray.

Attachment A contains a description and justification of the proposed l

changes. Attachment B contains marked up Technical Specification pages and a copy of the retyped Technical Specification pages.

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,i30 The proposed changes have been reviewed and approved by both onsite and offsite review in accordance with 10 CFR 50.92 (c).

Commonwealth Edison

' has determined that no significant hazards consideration exists and has performed an Environmental Assessment.

Documentation of these reviews is contained in Attachments C and'D.

Commonwealth Edison is notifying the State of Illinois of this ~

application for amendment by transmitting a copy of'this letter and its attachments to the designated state official.

1 Please direct any questions regarding this matter to this office.

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.{

Very truly yours, R. A. C rzanowski Nuclear Lic neing Administrator Attachments:

1) Description and Justification of Changes B) Marked ty) Technical Specification Pages and Typed Technical Specification Pages.

C) Evaluation of Significant Hazards Consideration D)- Environmental Assessment cc:ECEPates-NkUP

• "R$sidentiInsped$or - Zion Region III Office Office of Nuclear Facility Safety - IDNS l

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ATTACHMENT A.

l Description and Justification of Changes to TSC 90-01 The Containment: Spray System is designed to furnish containment atmosphere-cooling to limit post-accident pressure and temperature to.'less than design limits.

In' addition <the Containment Spray System operates to inject sodium a

hydroxide solution into'the spray' water.- The injection of sodium hydroxide ensures that the pH of the solution injected and later recirculated'from'the containment recirculation sump is alkaline.

This will aid.in minimizing-chloride and' caustic stress corrosion and enhance the ability lof the spray _to scavenge iodine fission products from the containment atmosphere.- ~ The.'

Containment Spray and Sodium Hydroxide Addition systems are= evaluated as l

separate systems because of the differin 6 functionsLthey provide.

~

Zion Station Containment-Spray System is unique when compared to 'other Containment Spray Systems. The pressure reduction and iodine removal functions of the system are fulfilled by 3~ independent,1100% capacity trains.

(ref. Figure 1).

The recirculation phase function is fulfilled by 2 100%

~

capacity systems (ref. Figure 1 & 2).

The Containment: Spray Recirculation Phase System does.not utilize.the containment spray. pumps.

In this phase of-operation, the containment spray pumps will be shutdown and the Residual Heat Removal (RHR) pumps will supply water from the containment recirculation: sump to the containment spray headers via the. containment spray valves CS-0049 or CS-0050.

Operation'of the Containment Spray 1 System is dividedTinto two distinct phases of operation, injection and recirculation.. During the initial stages of an accident, containment spray water is-supplied from'the Refueling-Water.

Storage Tank (RWST), this is considered to be the injection. phase'for containment spray.

The injection phase-for containment = spray will continue-until the RWST is emptied. At this time, the Containment Spray Recirculation Phase System may be placed in operation to continue containment spray function.

The pressure reduction and iodine removal function of the Containment-Spray System actuate simultaneously upon initiation. The pressure reduction l

function of the Containment = Spray System is maintained in. operation using all j

3 pressure reduction systems until containment. pressure is reduced to less than 20 psig. When pressure is reduced to less than 20 psig,;the operator is instructed by Emergency Operating Procedures to secure all ~ but'l of the l-pressure reduction spray systems. Operation in.this; mode is continued until the RWST is emptied, at which time the Containment Spray Recirculation Phase System is placed into service. Operation of the sprays will' continue until 4

containment pressure is reduced to less than 6 psig.

If the-event is n' primary system LOCA, spray operation will bontinue for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to scavenge iodine fission' products from the containment atmosphere. At this time the sprays will be terminated.

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,The 16 dine removal function is actuated whenever the Containment Spray System is started'. The' sodium hydroxide solution is added to the spray water from the Spray Additive Tank. This addition will continue until the Spray Additive Tank is-empty, at which time ~the Spray Additive Tank to eductor stop valves are closed. Through full injection of the Spray Additive-Tanks content, the containment recirculation sump will achieve an alkaline pH.-

The current Limiting-Condition For Operation (LCO) 3.6.1,' Containment-Spray System, identifies operability requirements for the Containment Spray System.during the injection phase of. Containment Spray-Actuation. :It defines

- the operability requirements of the Containment Spray-System for providing pressure reduction and iodine removal.

However, LCO 3.6.1'does not. clearly define the requirements of providing containment spray during the recirculation phase of operation.

LCO 3.6.2 ic being proposed requiring "Two Containment Spray Recirculation i

Phase Systems to be operable and capable of.providing containment spray with-water supplied by independent Residual Heat Removal Pump Systems taking suction from the containment recirculation sump.- This LCO will.be applicable during Modes 1, 2, 3 and 7.

-This.is-consistent with the current modes of-applicability for the Containment Spray and RHR Pump Systems.

Index page-11 has been revised to account for the addition of this new LCO.

The action statement associated with the Containment Spray Recirculation Phase System will allow continued operation'for a periodEof time not to exceed 7 days as long as at least 3 Reactor Containment Fan, Coolers (RCFCs) are operable. The 7 day ' period and shutdown time; f renes are consistent with LCO 3.8.3, for the RHR Pump System.

In addition, the 7 day; allowable outage time frame is considered to be a logical extension of the existing 7. day allowable outage time for the RHR Pump System.

This time frame is'further justified-by the relatively insignificant contribution that the recirculation phase. system-has on containment pressure response. The requirement to assure at least 3 RCFCs are operable, is based on an analysis performed showing containment pressure response. This is felt to be a conservative action because it is linked only to the recirculation phase requirements which by this time containment pressure will have been significantly reduced.

For the injection phase pressure reduction and iodine removal functions, the requirement to have at least 4 RCFCs operable, if either function is found'to.be inoperable, will remain the same. The results of the analysis conducted are as shown in r

! to this attachment. With regards to iodine removal, itihas been L

shown that spray additive plays a relatively minor role in iodine removal.

Studies by Westinghouse (WCAP 11011) have shown that elemental iodine 1is removed from the atmosphere and deposited onto containment surfaces regardless of the spray pR.

The organic forms of lodine are net easily removed by sprays, and are assumed to be removed by decay only.

Particulate iodinesis removed by sprays and also through decay.

l-It should be noted that the FSAR does not take credit for iodine removal in the recirculation phase of operation.

In addition, the Zion Station Probabilistic Safety Study does not take credit for recirculation phase operation at all. These allowable outage times will provide for adequate time l

to effect repairs to inoperable components prior to requiring a unit shutdown.

In the event the system continues to be inoperable after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in Hot Shutdown, the unit shall be placed in Cold Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2

Surveillance requirements for Containment Spray Recirculation Phase System-comp,onents shall be in accordance with Zion Station Inservice Testing Program for ASME Code Class 1, 2 and 3 pumps and. components. The Containment Spray'

• valves CS0049 and CS0050 are the only active' components not currentlyftested by either the Containment Spray System or the RHR Pump System Technical' Specification. As such, the IST pro 6 ram requirements are the only testing requirements-found to:be applicable.

Table 4.6-1 Containment Spray System Components has been revised to Include RHR Train to lA(2A) & IB(2B) Header Stop Valves (MOV-CS-0049 &

MOV-CS-0050). The component noun names in this table have also been revised i

to reflect new labeling as part of Zion Station's Detailed Control Room Design-Review ProBram.

The' Basis for Section 3/4.6 Containment Spray has been revised to include the following; New paragraph describing operation of containment spray in the 1

1) recirculation phase including reference to applicable FSAR section 6.4.2.

2)

New paragraph providing-justification for a.7. day inoperable-period for one Containment Spray Recirculation Phase System.

3)

Revised paragraph in Basis 4.6 to include Containment Spray Recirculation Phase System components and reference'to testing

-(

. periodicity. Changes to the testing frequency are' required to address the differences between the current Technical Specification testing' frequency for the Containment Spray System'and the Containment Spray Recirculation Phase System.-

4)

Other minor changes have been made' These changes are editorial in nature, made to improve readability of the basis. None of these changes alter,the intent'of this section.

l The basis for Section 3/4.8 has been revised to include a. paragraph describing the operation of the Emergency Core Cooling. System during the l

recirculation phase includin6. reference to applicable' FSAR section 6.2.2.1.3.

This paragraph states the purpose of the RHR Pump System to provide recirculation water to the Containment Spray-Recirculation Phase System.

Other minor changes have been made which are-editorici in' nature and made to.

improve rendability of the basis. None of-these changes' alter the intent of this section.

L In conclusion, the new LC0 addressing Containment Spray Recirculation System and the new paragraph describing the-functional. requirements of the ECCS system during the recirculation phase of operation, will improve-the L

overall safety of the plant by providing better operability decision making l:

process in regards to Containment Spray.

(Zion Station Containment Response with Loss of RHR Spray During LOCA RSA-2-89-03, June 23, 1989)

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ATTACHMENT B 1.

Copy of current Technical Specifications.pages 11 1153 154

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Copy of Revised pages:-

111 153

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154 155:

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$URVEILLANCE b

REQUIREMENT PAGE t Illi!ING CONDII10N f UR tlPIRATION

'4.0-Z ia 3.o W neral 71c n.t s e s l< eat tor Protec tion Instrumentation and Logic 4. I '.

28 g

3.I 37' 1ases Q

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i!eactivity Control and Power Distribution 4.2 39 4.2.1 39 3.7.1 Rea(11vity Control J.2 ?

rower Distributton Limits

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45 3.2.3 Lontrol Rod System Operah111ty (per unit) 4.2.3 51 3.2.8 DNU Parameters 4.2.4 55

'64 liases 3.3 Reactor Coolant System (per unit) 4.3 73 3.3.I Uperatlonal Components 4.3.1 73 77b.

fiases 3.3.2 Pressurization and System Integrity 4.3.2 79 90 Bases 3.3.3 ieakage (per unit) 4.3.3 95 Bases 9e.

3.3.4 Structural Integrity 4.3.4 99 -

Bases 118 3.3.5 Chemistry (per unit) 4.3.5

-120 Bases

'122 3.3.6 Specific Activity

-4.3.6 123 Bases 125 3.4 Safeguards Instrumentation and Control 4.4 127 Bases

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,j3.5 Reactor Containment Fan Coolers 4.5 '

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Component Cosaponent Corsponent ' Name Number Comnonent Name

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' Containment Spray Pump 1A (2A)

CSOOl-1A (2A)

Containment Spray Pump-lC(2C)

CSOOO3-lC(2C -

(motor. driven)

(diesel driven) th.x w cm 5,vM R nP /r1/54) odenAG&s

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/A On1 K'HC TswJ To 1A (A kc82e 5tw flk.V - C'SOO 49 slewt Containment Spray Pump to (ud CSOO2-13 (2B)

(motor driven)

($sua JNMr $hr' /%P 18Nd disceni Spray :::;d:

V;17 rmaw s/#8 A MOV-CS0004 Sird Y Anso nJa Tc. /& Nts) &aerif SW

[ rd :ter C;; tion Vrive vritte MOV-CS 000'J*

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reduction and iodine removal capability,

Y ayrds designed to since the remaining two containment

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3.6 The d ntainment _

s spray r, umps and four containment faa

.i reduce containment pressure and to remove

, coolers will be operational {

<y, lodine. froir. the containment atmosphere.4g.,,,A j

/fggg y-The heat re9 oval capacity of onetspraypump/fd/pffAf[,isatleastequivalenttaj f

The - tiL'e established for the spray -

t tige for additive / pnk la based on tha the heat removal capacity of three' fan WW/ M Md of the reactor.

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j coolers (1).

The system is designed to f

deliver s ith only ona(pump running, d['[' '"'d--

i more desiracle to complet( the repair' i

of-the tank than' to undery',M,M

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enou s NaOH solution +to the containment fueling water and spilled reactor coolant e/ w A )

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sients involved with,ggd.I'd

'N to form an 8.8 Ph solution in the re-1 wpter 'after the fefueling dater /torage The 40 ah os supplysof diesel fuel fank haobeen emptied. (4 The final supplies sufilcient rub time to insure

f ggf) solution which-will contain O.6 weight that the RWST is empty before the.spea;iti r.,1 -

percent of NaOH in the containment M ese,1 runC out of fuel.

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will insure that ths removal rata of' d*.=rf h Aao s

ia ine will be as stated in,$ Action (1)- PSAR, Figure 14.3.4-12 i

l 14.3.5.4 of thq F$tR, and D11 Core-vent the ?ebec tiHga61on of iodine (2)

PSAR Section 6.4

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upon recirculation fro.h the sump.

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(,. g. 2 The containaent pressure reduction.

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anelysis in based on the operation of F f/4 #a>sr s/M 5 j,nen two, spray pumps and three containment,

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,u.,, c..a B.ec fan coolers (3).

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r the three epray pumps'for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

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- C h to verify that f

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'y the pumps are la satisfactory running I

order and that the valves are free to l

move.

The test interval is based on the M ement that more frequent testing would not significantly increase the reliability and would result in increased wear over a long period of time.

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The refueling outage systes test' e

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demonstrates proper automatic operation j

i of the Containrynt Spray System.

With the pumps blocked from. starting, a test H

signal is applied to laitiate automatic action and veriTAcetiou is made the.t the

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'a c _ _--:-m.ts# received the signal.

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test demonstrates the operation of the automatic. circuitry, the valves, and pump _ circuit breakers.

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I Verification of NaOH concentration each 3

querten is more than pequate to verify l

Its avallebility because of the extreeely-stabic netsfre of this soluties.

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Bases 3.8 and 4.8 (Continuedl I

The availability of the systems is demonstrated by The pressure and volume limits for the accumulators. I'i i

Immediately demonstrating the OPERA 8ILITY of the assure that the required amount of water is injected P.

components redundant to the failed one, as.we11 as with the regstred boric acid concentratten following l

the OPERABILITY of the inter-related systees and a loss-of-roolant accident. The 11 sits are based on j

the standby.*C and DC power supplies that feed the values used for the accident analyses. (4) l I

them. The continued avallebility of these p

L components during the repair period is demonstrated The five component cooling system pumps and three by repeating these tests daily.

heat exchangers are located in the Auxillary Building I

and are~a shared system between Units I and 2.

The l

Assuming a reactor has been OPEM TING at full re ed components are accessible for repair after a l

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power for at least 100 days, the aegnitnie of the loss-of-coolant accident.J0:ringdh rectrculation

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decay heat decreases after initiating MODE 3.

ph4se following a los>.o[.-coolant accident on a unit, Thys, the requirement for core cooling in case of a only one component cooiing pump and heat enchanger is l"

postulated loss-of-coolant accident while in the required for minimum safeguards of that unit.

E)DE 3 condition is significantly reduced below the Therefore, a slaluum requirement of four component requirements for a postulated loss-of-coolant cooling pumps and three heat enchangers for.two f'

accident during PONER OPERATION. Putting a reactor OPERATING units provides sufficient redundancy. (5) ];

in the MODE 3 condition significantly reduces the potential consequences of a loss-of-coolant A total of six service water pumps are installed, t

2 accident, and also allows more free access to some only one service water peg is required lamediately --

of the engineered safeguards components in order to following a postulated less-of-coolant accident. (6)

[

l-effect repairs.

(See p. Ig5)

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" 7G "'* 2 f'*~

G* W AMS Failure to complete repairs within the allowable M but SMe (d<6 ) du/<y t.A, owe rms p,.,,.3r, ya time after going to the MODE 3 condition is considered indicative of a requirement for major n r-Av,nermai,w x

<w s m n,g u n,,,, m,

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1. -sev5 wr I, e.., r. n m u w7w !

maintenance and therefore in such a case, the do=w s-n,,,,"e f

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reattor in general is to be put into the MODE 5 rpm

,,w,,, gy,y,,,g g4 condition.

figy m s g_ g jgg,,,

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1. #E dd8 * * * '

The limits for the accumulators and refueling water A'"O

'^* I^*' A' ( * #^**W storage tank insure the required amount of water A

M W d'W*/WA ME ^> TJe //ru.en..

l with the required boron concentration is available for injection into the primary coolant system 6TS FM 4.)44 A-

1. n# A/vo SI A,gies maf fp i

following a loss-of-coolant accident and are based Al s9a c w l)

Tb wr Ic 4 gn.,pafom f,<g on the values used for the accident analysis (4).

Ehw M hc f y maa mm 5

W W/s)$ ffarEOrfE$.

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P Bases 3.8 and 4.8 (Continued)

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t l

The k h h 7 ef the [ervice h ier Iystem ensures The channel calibration af the hydrogen monitors that sufficient cooling capacity 1s avaliable for regstres disassembly and electronic testing.

continued operation of safety related egulpment adjustment and reassently of the instrument l

during normal and accident condittens. In the therefore the refueling cycle frequency is deemed split discharge header /dM//fM saede (Unit 1 & 2 afeguate.

4 j-with separate discharge headers), two /////IIM i

pumps and one standby are required for normal The Instrumentation, egulpment, and pJocedures for ration In the cross-tied discharge header t)e testy which are required on the #ent11ation

' ///fM ode (Unit 1 & 2 with cemen discharge filter fystem will generally confers to the header), three pumps have sufficient c 1ty/,

for recommendations of ANSI N510-1975.

/

normal operation but five pumps to be with only one pump from either unit satisfying this The OPERASILITY of the ace.1 dent monttering requirement for the other unit, are required to instrumentation ensures that sufficient infer==t1.n provide sufficient redundancy. In an accident or is available on seierted plant per==i-t-ri it.

+

shutdown mode, only one pump per untt 1s required.

monitor and asse3i th-3e ver Lehle3 ssins 2 s follawing e etcid ei.-

Thh ta:4billiv tv Forthe[ervicehter[ystem,the Mk (ans isiaevi wi th. ii== r et+====*=34i }*+ *f r ** tw1ai le y i

requirements include consteeration of-the standby Geld.1.9 7. *!=$1

-.i.O f, s_1.ghi.aister. Cooled AC & DC power supplies so that a single fallere of Mec1*er Pe=a-r rim,lv i As3 35 riant Condittens i

the *0" diesel will not cause a commen mode fa11ere 19eing and following an Accident," tecenter 1975 inthefervicefester/ystem;"0"dieselpowersthe and NURES-9578, *INI-2 Lessons tearned Task Forve emergency besses for service water punrs 1A and 2A.

Status Report and Short-Tern Recesumendattens'.

3 fl A [ydrogen Recombiner [ystem is installed to remove i

i the hydrogen and oxygen gases that accumulate in

{ ;p the containment atmosphere following a a ipss-of-coolant accid at. (7) The containment (1) FSAR Chapter 9 f

y #ydrogenfonitoringJystem1susedtodeterminethe (2) f54R Section 6.2 effettiveness of this system.

(3) FSAR 5ectlen 6.2.3 o

'l (4) FSAR 5ectlen 14.3 l

[

(5) FSAR Section 9.3 (6) FSAR 5ectlen 1.6 & FSAR answer te guestion 9.1 0

(7) FSAR 5ectlen 6.8 y SM [.2)./ j 0792t/0793t 195 0355A 4

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SURVEILIANCE LIMITING CONDITION FOR CPERATION REQUIREMENT PAGE 3.0 General 4.0 27a Bases 27c 3.1 Reactor' Protection Instrumentation and Iogic 4.1 28 Bases 37 3.2 Reactivity Control and Power Distribution 4.2 39 3.2.1

. Reactivity Control 4.2.1 39 3.2.2 Power Distribution Limits 4.2.2 45 3.2.3-Control Rod System Operability (per unit) 4.2.3 51 3.2.4 DNB Parameters 4.2.4 55 Bases 64

3.3 Reactor Coolant System (per unit)-

4.3 73 3.3.1 Operational Components 4.3.1 73 Bases 77b 3.3.2 Pressurization and System Integrity 4.3.2 79 Bases 90 3.3.3 Leakage (per unit) 4.3.3 95 Bases 9g

.3.3.4

-Structural Integrity 4.3.4 99 Bases 118 3.3.5' Chemistry (per unit) 4.3.5 -

120 Bases-122

-3.3.6 Specific Activity 4.3.6 123 Bases 125 3.4 Safeguards Instrumentation and' Control' 4.4 127 Bases 144 3.5 Reactor Containment Fan Coolers 4.5 146 Bases 148 3.0 Containment Spray 4.6 150 3.6.1 Containment Spray System 4.6.1 150

-- 3.6. 2 -

Containment Spray Recirculation Phase System 4.6.2 152a Bases 154 TABLE OF COffrENTS (Continued)

/0940T ii TSC 90-01

..a.

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4 COMPONENT NAME COMPONENT NLMER Containment Spray Pump 1A (2A) (Motor Driven)

CS001-1A (2A)

Containment Spray Pump 1A(2A) Discharge Isolation MOV-CS0002 Valve l

Spray Additive to IA(2A) Eductor Stop Valve MOV-CS0008

• l Containment Spray Pump 1A(2A) Header Stop Valve MOV-CS0003 l

1A(2A) RHR Train to 1A(2A) Header Stop Valve MOV-CS0049 #

l Containment Spray Pump IB (2B) (Motor Driven)

CS002-1B (23)

I Containment Spray Pump 1B(23) Discharge Isolation MOV-CS0004 Valve 4

Spray Additive to IB(2B) Eductor Stop Valte MOV-CS0009

• l Containment Spray Pump 1B(2B) Header Stop Valve MOV-CS0005 l

IE(2B) RER Train to IB(2B) Header Stop Valve.

MOV-CS0050 #'

Containment Spray Pump IC (2C (Diesel Driven))

CS003-1C ( 1 )

Containment Spray Pump IC(2C) Discharge Isolation MOV-CS0006-Valve l

Spray Additive to IC(2C) Eductor Stop Valve MOV-CS0010

• l Containment Spray Pump IC(2C) Header Stop Valve MOV-CS0007.

Iodine Removal only l

1. Containment Spray Recirculation Phase System only.

Containment Spray System Components TABLE 4.6-1

- 18310/18450 l153 TSC 90-01 c.

Basir. :

' 3.6 The Containment Spray System is designed to reduce containment pressure and to remove iodine from the containment atmosphere. The heat removal capacity of one containment spray pump CPERATING, is at least equivalent to the heat

. removal capacity of three containment fan coolers (1).

The system is designed to deliver, with only one containment spray pump running, enough NaOH solution to the containment to form an 8.8 pH solution in the refueling water and spilled reactor coolant water after the Refueling Water Storage Tank (RWST) has been emptied (2). The final solution which will contain 0.6 weight percent of NaOH in the containment will insure that the removal rate of iodine will be as stated in Section 14.3.5.4 of the FSAR, and will prevent the revolatilization of iodine upon recirculation from the sump.

The containment pressure reduction analysis is based on the operation of two containment spray pumps and three con tainment fan coolers (3). The loss of one of the three containment spray pumps for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is justifiable in terms of pressure reduction and iodine removal capability, since the remaining two containment spray pumps and four containment fan coolers will be operational.

The RWST rupplies borated water to the Containment Spray during the injection phase.

In the recirculation phase of containment spray operation, the source of water to the containment spray headers may be transferred to the Residual Heat Removal System (RHR). The RER System is capable of supplying water f rom the containment recirculation sump to the two Containment Spray Recirculation Phase Systems (4). Operation of containment spray in the recirculation phase is controlled by the operator using Emergency Operating Procedures.

The loss of one of two Containment Spray Recirculation Phase Systems for 7 days is justifiable in terms of pressure reduction and iodine removal capability, since the remaining Containment Spray Recirculation Phase System and at least three reactor containment fan coolers will be operational. A repair period of 7 days has been developed based upon:

1) assuring with high reliability that the Containment Spray Recirculation Phase System will function if required to do so, and 2) is compatible.with the same period for an inoperable RHR Fump System (Specification 3.8.3.D), which provides the source of water to the system.

The time established for the spray additive tank is based on the time for COLD SHUTDOWN of the reactor.

It is more desirable to complete the repair of the tank than to undergo the transients involved with going to COLD SHuTo0WN.

The 40 gallon supply of diesel fuel provides sufficient run time to insure that the RWST is empty before the l

diesel-driven containment spray pump runs out of fuel.

(1) FSAR, Figure 14.3.4-12 (3) FSAR Section 14.3.4 (2) FSAR Section 6.4 (4) FSAR Section 6.4.2.

l 18310/18450 154 TSC 90-01

..if 4

Basts:

4.6 The active components of the Containment Spray Systems and the Containment Spray Recirculation Phase Systems (pumps and valves) are periodically tested to verify that the pumps are in satisfactory running order and that the valves are free to move.

The test interval is based on the judgment that more frequent testing would not significantly increase the reliability and would result in increased wear over a long period of time.

~

The refueling outage system test demonstrates proper automatic operation of the Containment Spray System..With the pu p blocked from starting, a test signal is applied to initiate automatic action and verification is made a

j that the components have received the signal. This test demonstrates the operation of the jutomatic circuitry, the valves and pump circuit breakers.

e Verification of NaOH concentration each quarter is more than adequate to verify its availability because of the extremely stable nature of this solution.

18310 155 TSC 90-01

Bases 3.8 and 4.8 (Cont'd )

The OPERAEILITY of the Service Water System ensures The channel calibration of the hydrogen monitors that suf ficient cooling capacity is available for requires disassembly and electronic testing, continued operation of safety related equipment adjustment and reassembly of the instrument during normal and accident conditions.

In the therefore the relueling cycle frequency is deemed rplit discharge header OPERATING mode (Unit 1 & 2) adequate.

with separate discharge headers), two OPERATING pumps and one standby are required for normal The instrumentation, equipment, and procedures for operation.

In the cross-tied discharge header the tests which are required on the Ventilation Filter OPERATING mode (Unit 1 & 2 with common discharge System will generally conform to the recommendations header), three pumps have sufficient capacity for of ANSI N510-1975.

normal operation but five puaps to be OPERABLE, with only one pump from either unit satisfying this The OPERABILITY of the accident monitoring requirement for the other unit, are required to instrumentation ensures that sufficient information provide sufficient redundancy.

In an accident is available on selected plant parameters to monitor er shutdown mode, only one pump per unit is required.

and assess these variables during and following an accident. This capability is consistent with the For the Service Water System, the OPERABILITY recommendations of Regulatory Guide 1.97, requirements include consideration of the standby

" Instrumentation for Light-Water-Cooled Nuclear Power AC & DC power supplies so that a single failure of Plants to Assess Pirnt. Conditions During and Following the "0" diesel will not cause a cosmon mode failure an Accident," December 1975 and NUREG-0578, "TMI-2 in the Service Water System; "0" diesel powers the Lessons Learned Task Force Status Report and Short emergency busses for service water pumps IA and 2A.

Term Recommendations".

A Hydrogen Recombiner System is installed to remove the hydrogen and oxygen gases that accumulate in the contain-ment atmosphere following a loss-of-coolant accident.

(7)

The containment Hydrogen Monitoring System is used to determine the effectiveness of this system.

(1) FSAR Chapter 9 (2) FSAR Section 6.2

'(3) FSAR Section 6.2.3 (4) FSAR Section 14.3 (5) FSAR Section 9.3 (6) FSAR Section 9.6 & FSAR answer to question 9.1 (7)~ FSAR Section 6.8 (8) FSAR Seetion.6.2.2.1.3 l

TSC 90-01 18310 195

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.6.2 CONTAINMENT SPRAY RECIRCULATION PHASE SYSTEM:

4.6.2 CONTAINMENT SPRAY RECIRCULATION PEASE SYSTEM (Table 4.6-1):

A. Two Containment Spray Recirculation Phase Systems

~

A.

Surveillance and testing of the Containment shall be OPERABLE and capable of providing Spray Recirculation Phase Systems components containment spray with water supplied by independent (MOV-CS0049 & MOV-CS0050), shall be Residua.1 Heat Removal Pump Systems taking suction performed in accordance with the Inservice from the containment recirculation sump.

Testing Program for ASME Code Class 1, 2 and 3 pumps and valves per Section XI of the APPLICABILITY: MODES 1,2,3, and 7 ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10CFR50 ACTION:

With one Containment Spray Recirculation Phase Section 50.55.a(g), except where specific System inoperable and at least three rear. tor written relief has been dranted by the NRC containneent fan coolers OPERABLE:

pursuant to 10CFR50, Section 30.55.a(g)(6)(i)

Restore the inoperable system to an OPERABLE a.

status within 7 days, or

b. Be in Mode 3 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and after a maximum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in MODE 3, be in MODE 5 within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

/0940T 152a TSC 90-01 w-.-

n se l

ATTACEMENT C EVALUATION OF SIGNIFICANT RAZARDS CONSIDERATIONS i

Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10CTR 50.92(c), a proposed amendment to an operating license-involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment would nott 1.

Involve a significant increase in the probability or consequences of an accident previously evaluatedt or 2.

Create a possibility of a new or different kind of accident from any accident previously evaluatedt nr 3.

Involve a significant reduction in a margin of safety.

This proposed change does not result in a significant increase in the probability or concequences of accidents previously evaluated.

The probability for an accident is independent of the changes being proposed.

The Containment Spray Recirculation Phase System function is not a precursor to any accident assumed in the Final Safety Analysis Report. The function of the Containment Spray Re irculation Phase System is to mitigste the consequences of an accident. Therefore, through the establishment of a Limiting Condition For Operation, the consequences of an accident will remain the same.

The proposed change involves the development of a new specification defining the requirements of the Containment Spray System during the recirculation phase of operation. This Limiting-Condition For Operation has been established to assure that the lowest level of functional capability'and performance required for safe operation of the f acility is met. Remedial actions have been specified to require a plant shutdown when a Limiting Condition For Operation is not met.

Through theme actions, the consequences for an accident would l

remain within the limits established in the Final Safoty Analysis Report.

The remedial actions specify an allowable outage time period not to exceed 7 l

days. This time period is acceptible based on the philosophy of allowing a single level of degradation without total loss of functional capability. This level of degradation is conservative based on= the saf ety f unction of the system, and the allowable outage time period specified for other Engineered Safety Features of similar safety significance.

Surveillance requirements have been specified to assure that the system and components are tested routinely.

These tests will assure that facility operation will be maintained within the Limiting Conditions For Operations.

This specification has been derived using the analyses and evaluations included in the Final Safety Analysis Report.

This proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

It does not involve I

the addition of any new or different type of equipment, nor does this change involve the operation of equipment required for safe operation of the facility in a manner different from those addressed in the Final Safety Analyses Report.

/0940T 1

i

EVALUATION OF SIGNITICANT RAIARDS CONSIDERATIONS (Continued)

The proposed change does not involve a significant reduction in a margin of safety. This change is being proposed to provide a clearly defined t

Limiting Condition For Operation for the Containment Spray System during the recirculation phase of a Loss-of-Coolant-Accident (LOCA). The allowable outage time periods are consistent with these used for' systems of similar safety significance at Zion Station.

In the recirculation mode of operation, the Residual Heat Removal (RHR) Pump System, a part of the Emergency Core.

Cooling System (ECCS), supplies the recirculation water to the Containment Spray Recirculation Phase System from the containment recirculation sump.

Therefore, the allowable outage time periods have been selected to be consistent with the RHR Pump System. The Containment Spray Recirculatiren Phase System includes a requirement to verify at least 3 RCFCs are operable.

Analyses have been performed demonstrating that a total loss of containment l

spray during the recirculation pnase, would not result in a significant l

increase in containment pressure. The RCFCs can accommodate the assuned post-LOCA heat loads. Loss of containment spray recirculation f unction does '

result in an increase in temperature and pressure, but these increates are well within all design limitations and margins,

(

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/0940T 2

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ATTACHMENT D Environmental Assessment Statement This proposed Technical Specification amendment o'oes not involve a change in the installation or use of the facilities or components located within the Restricted Area as defined in 10CFR20.

Commonwealth Edison >3s determined that this Technical Specification amendment involves no sign./icant increase.

In the amounts, and no significant change in the types of any effluents that-may be released offsite and that there is no exposure. Accordingly, this Technical Specification amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR Section $1.22 (c)(9).

Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the granting of this Technical Specification amendment.

i I

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-a

Bases 3.8 and 4.8 (cont'd)

The availability of the systems is demonstrated by The pressure and volume limits for the accumulators ~

immediately demonstrating the OPERABILITY of the assure that the required amount of water is injected 4

I components redundant to the failed one, as well as with the required botic acid concent. ration following a the OPERABILITY of the inter-related systems and loss-of-coolant accident. The limits are based on the 4

the standby AC and DC power supplies that feed them.

values used for the accident analyses..

(4) 3 The continued availability of these components during the repair period is demonstrated by repeating these The RWST supplies borated water to the Emergency Core i

tects daily.

Cooling System (ECCS) during the injection phase.

In i

the recirculation phase of operation, the two Residual Aasuming a reactor has been OPERATING at full rated Heat Removal (RER) pumps ar ; realigned to take sectica power for at least 100 days, the magnitude of the from the containment recirculation sump. The RM pumps d: cay heat decreases after initiating MODE 3.

Thus, may then be aligned to supply recirculation water to the requirement for core cooling in case of a postulated the Containment Spray Recirculation Phase Systems, and l

lors-of-coolant accident while in the MODE 3 condition is to the Safety Injection (SI) pumps and Centrifugal significantly reduced below the requirements for a Charging pumps for cold leg recirculation. Later in postulated loss-of-coolant accident during POWER the accident, ECCS flow from the RER and SI pumps may OPERATION. Putting a reactor in the MODE 3 condition be realigned to hot leg recirculation. These significantly reduces the potential consequences evolutions are done in accordance with Emergency of a loss-of-coolant accident, and also allows enore f ree Operating Procedures.

(8) access to some of the engineered safeguards components in order to effect repairs.

The five component cooling system pumps and three heat exchangers are located in the Auxiliary Building and 4

Failure to complete repairs within the allowable time are a shared system between Units I and 2.

The cf ter going to the MODE -3 condition is considered indica-components are accessible for repair af ter a tive of a requirement for major maintenance and therefore loss-of-coolant accident. During the recirculation l

is such a case, the reactor in general is to be put into phase following a loss-of-coclant accident on a unit, thq MODE 5 condition.

only one component cooling pump and heat exchanger la required for minimum safesteerds of that ' unit.

The limits for the accumulates and Refueling Water Storage Therefore,a minimum reqeirement of four component Trnk (RWST), insure the requirt4 amount of water with the cooling pumps and three heat exchangers for two required boron concentration is available for injection OPERATING units provides sufficient redundancy.. (5) into the primary coolant system following a loss-of-coolant accident and are based on values used for the a total.of six service water pumps. are installed; only accident analysis (4).

one service water pump is required immediately following a postulated loss-of-coolant accident.

(6)

(See p.195) 18310~

194 TSC 90-01

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.