ML20042F469
| ML20042F469 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 04/26/1990 |
| From: | Schuster T COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| 0181T:17-18, 181T:17-18, NUDOCS 9005080359 | |
| Download: ML20042F469 (5) | |
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Commonwcalth Edisen i
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Downers Grove, tillnois 60515
- 1400 Opus Place
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t April 20, 1990 (Reissue, dated April 26, 1990 to correct letter date.)
Dr. ~ Thomas E. Murley Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commisrion Washington, DC 20555 Attnt Document Control Desk
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Application for Amendment to Facility Operating Licenses NPF-37/66 L NPF-72/77 NRC_D.orkeLNoo_$9:MALM5_1.A51/M7 Dear Dr. Murley pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend Appendix A, Technical Specifications of Facility Operating 1.icenses NTF-37 L 66/NPF-72 & 77 f or Byron /11raidwood Stations. The proposed amentiment revises Specif1 cation 3/4.63, Containment Isolation Valves, to delete the requirement f or type C lerkage testing for specifled Steam Generator blowdown isola!.lon valves and to insert a requirement for the type C Icakage test for the 1/2 SIB 968 safety injection valves.
The description and bases of the proposed channs are contained in Attachment A.
The revised Technical Specification page, are contained in Attachment B.
The proposed changes have been reviewed and approved by both on-site and off-site review in accordance with Commenwealth Edison procedures and Technical Specifications. Commonwealth Edinon has reviewed this proposed amendment in accordance with 10 CFR 50.92(c) and has determined *. hat no significant hazards consideration exists. This evaluation is doc 4mented in Attachment C.
An Environmental Assessment has been performed and is included in Attachment D.
Commonwealth Edison requests approval of this proposed amendment by September 1, 1990, in support of the second refueling outage for Byron Unit 2.
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- :.2 April 20, 1990 1
Commonwealth Edison is notifying the State of Illinois-of our application-for this amendment by transmitting a copy of this letter and its attachments to the' l
designated State Official.
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Please direct any questions you may have concerning this matter to this office.
l Very truly yours, i
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/La-* T. K. Schuster Nuclear Licensing Administrator i
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Attachments: A) Description and Bases of the Proposed Changes
)
s-B) Proposed Technical Specification Changes j
i C).. Evaluation of Sigulficant flazards Consideration-L D) ' Environmental Assessment Statement Applicability Review
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t f-l; cet Resident Inspector - Byron Resident Inspector - Braidwood P.C. Shemanski - NRR
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S.P. Sands - NRR i
Regional Administrator - Region III L
Office Of Nuclear Facility - IDNS 4
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L'1, AITACEMENT..A DEECRIIIIDtLAND_ BASES OF THE FR0ffSED CHANCES DESCRIPTION The proposed changes to Technical Specification 3/4.6.3, Containment Isolation Valves, specifically Table 3.6-1, pp. 3/4 6-18 and 3/4 6-24, delete the requirement f or type C leakage testing on Steam Generator Blowdown valves SD002A through H and SD00$A through D, and add the requirement for type C testing for The Lirst proposed change is accomplished by the Safety Injection valve SIB 968.
inclusion of an asterisk ("*") af ter each valve number, which references the
"* Not subject to Type C leakage tests.".
The stCond proposed change statement corrects an editorial error by removing the "*" placed af ter the "SI6968" valve, since type C testing is required for SIB 968 and has always been done despite the referenced "*" placed by the valve.
EASEE_0E_IllE_PROI.0 SED _CilA!iGES The bases for containment isolation valves Technical Specification 3/4.6.3 is that "the operability of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or (Technical Specification 3/4.6.3 Bases, page B pressurization of the containment."The containment isolation system is designed to 3/4 6-4).
Containment requirements of GDC 54 through 57 of Appendix A to 10CTR Part 50.
itolation times ate also specified for the isolation valves designed to This " ensures that the release of radioactive material to the automatically close.
environment will be consistent with the assumptions used in the analysis for a LOCA" as stated on page B 3/4 6-4.
Technical Specification 3/4.6.1.1, Containment Integrity, and 3/4.6.1.2 Containment Leakage, (see bases on page B 3/4 6-1) " ensures that the release of radioactive materials from the containment atmosphere will be restricted to those and leakage paths and associated leakage rates assumed in the safety analyses' "that the total containment leakage volume wJl1 not exceed the value assumed in the The type B and accident analyses at the peak accident pressure, Pa" respectively.
C leakage testing required for the containment isolation valves (that meet the criteria per 10CTR50 Appendix J and are listed in Technical Specification 3/4.6.3),
As a result, containment ensures that containment leakage is within limits.
integrity will be maintained in the event of an accident as outlined in the UFSAR.
In the event of a steam generator tube rupture with some leakage past the SD valves, there would be no effect on the radiological release in the analysis since the most conservative assumption of no blowdown was used to maximize the L
radioactive isotopes in the steam generator.
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AIIACWiMI A_ICQliU The Steam Generator (SG) Blowdown lines transfer secondary side water to the SG Blowdown Systes (SD) for cleanup. The SG Blowdown System lines are neither a part of the Reactor Coolant System (RCS) pressure boundary nor do they open directly to the containment atmosphere under post-LOCA conditions. The intent of requiring the autoclosure of the SD valves on a containment isolation signal is to conserve the SG secondary side mass (heat sink) in the event of an accident and a phase A initiation. A future modification will add auto-closure of the SD valves on a Lo-2 SG 1evol for the same reason, to conserve mass. The valves are not relied upon to perf orm a containment isolation function as described per the Technical Specification 3/4.6.3 bases, and therefore, Appendix J of 10CTR50 does not require that they be tested for type C leakage.
For the same reason, the main steam isolation valves and the feedwater and auxiliary feedwater valves do not require type C testing.
This was previously agreed upon and is reflected in the original Technical Specifications.
Though the SD valves do not iall into 10CFR50 Appendix J item !!.11 categories 1, 2, and 4 of type C testing requirements criteria for containment isolation valves, the SD valves might be used and operated intermittently under post-accident conditions (category 3 of type C testing requirement criteria for containment isolation valves). This intermittent usage would include (1) sampling SG under post-accident conditions, and (2) RCS cooldown in the event no other alternative is available.
Neither of these uses are required for the mitigation of any accident aoslyzed in the update Final Safety Analysis Report (UFSAR).
In the event t, hat the valves are operated intermittently under post-accident conditions, the systems that they supply flow to are designed to handle post-accident secondary water.
These systems are the liigh Radiation Sampling System (llRSS) and the SD system via a blowdown condenser, a hotwell tank, pumps, and the blowdown demineralizer system.
Processing of the blowdown would be a monitored activity and radiation monitoring on the outlet of the blowdown demineralizers would alert the operators to abnormal conditions.
SG blowdown would not be initiated in the event of an accident until
.amples of the secondary system activity were taken and an isotopic analysis performed.
This would ensure that there would be no significant radiological concerns in establishing SG blowdown.
In the event that. the blowdown lines needed to be isolated during sampling or blowdown, menual isolation valves in series with the SD valves would be available. The SD piping is category I safety class B up to and including the SD isolation valves.
It is fer the above reasons that the SD valves do not f all into any of the f our (4) criteria f or type C testing l
requirements per Appendix J item 11.11 of 10CTR Part 50.
l The SD valves will still be functionally tested per Technical l
Specification 3/4.6.3 and required to be operable, in that stroke time limits and autoclosure on initiation of a phase A signal will still be required.
l Other licensee's Technical Specifications do not require type C testing for SG Blowdown valves In particular, Comanche Peak cites the basis for their exclusion as NUREG 0800 6.2.4.II.6.o. which describes a closed system in containment as qualifying for a containment isolation. This information is being provided as a reference since the Byron /Braidwood SG Secondary is also considered a closed system. For the reasons previously stated above, the SG Blowdown valves are exempt from type C testing as required for particular containment isolation valves.
The description and analysis above supports the proposed change that deletes the type C testing requirement for the SD valves.
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AIIAC M MT A (CQNI) l The deletion of an "*" to indicate that the S18968 valves do require e type C test corrects an error either typographical or editorial in nature.
By l
deleting the "*" an additional requirement is being added to the Technical Specification. Type C testing has always been required for valves SIS 968 per 10CrR50 Appendix J and has always been done. With the proposed change, the Technical Specification will be consistent with the requirement for type C testing for S!8968 valves.
t The proposed changes will more accurately reflect the testing requirements for the SD valves while better demonstrating overall containment isolation i
effectivenet.s by the deletion of type C testing for valves where this type of testing is not required.
The editorial change corrects an error in Technical Specification 3/4.6.3 whereby the actual testing requirement of valves already subjected to type C testing will be correctly indicated.
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PROPOSED CRANGES TO APPENDIX A.
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TECHNICAL SPECITICATIONS OF TACILITY OPERATING LICENSES NPT-37, NPT-66. NPT-72 AND NPT-77 ARAIDnl00D SIAIl0N BIRON_SIAIIDN EtYltti.IAgea!
3/4 6-18 Rexisad_Easati 3/4 6-18 3/4 6-24 3/4 6-24 i
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j TABLE 3.6-1 CONTAINMENT ISOLATION VALVES MAXIMUM i
PENETRATION VALVENg TUNCTION ISOLATION TIME (SEC) 1.
Phase "A" Isolation 28 CV8100 RCP Seal Water Return 10 t
i 28 CV8112 RCP Seal Water Return 10 1
41 CV8152 RCS Letoown 10 t
41 CV8160 RCS Letdown 10 t
s 5
W9020A Chilled Water 50 5
W9056A Chilled Water 50 6
W8006A Chilled Water 50 8
W8020B Chilled Water 50 1
8 W9056B Chilled Water 50 10 W9006B Chilled Water 50 t
22 CC9437B*
Excess Ltdn HX Return 10 48 CC9437A*
Excess Ltdn HX Supply 10 C
34 FP010" Fire Protection 12 39 IA065 Instrument Air 15
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39 IA065 Instrument Air 15 7
13 OG079 Hydrogen Recombiner 60 13 OG080 Hydrogen Recombiner 60
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13 OG082 Hydrogen Recombiner 60 13 OG084 Hydrogen RecomDiner 60
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23 OG081 Hydrogen Recembiner 60
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23 OG085 Hydrogen Recombiner 60
.l 69 OG057A Hydrogen Recombiner 60 69 OG083 Hydrogen Recombiner 60 i
56 SA032 Service Air 4.5 56 SA033 Service Air 4.5 80 50002C 4 Steam Generator Blowdown 7.5 c'
80 50005B +
Steam Generator Blowdown 3.0 81 50002D +
Steam Generator Blowdown
- 7. 5 s
I 82 50002A T Steam Generator Blowdown 7.5
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82 SD005A
- Steam Generator Blowdown 3.0 83 50002B +
Steam Generator Blowdown 7.5 88 S0002E
- Steam Generator Blowdown 7.5 r'
88
$0005C y-Steam Generator Blowdown 3.0 89 50002F v Steam Generator Blowdown 7.5 C l 90 SD002G $
Steam Generator Blowdown
- 7. 5 c
90 SD0050-ti Steam Generator Blowdown 3.0 91 SD002H.t Steam Generator Blowdown
- 7. 5 1
1 BYRON - UNITS 1 & 2 3/4 6-18 l-
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g TABLE 3.6 1 (Continued)
CONTAINMENT ISOLATION VALVES l
MAXIMUM PENETRATION VALVE NO.
FUNCTION ISOLATION _ TIME (SEC)
- 10. Check (Continued) 60 SIB 819C*
Safaty Injection N. A.
60
$188190*
Safety Injection N.A.
' - s 66 SIB 841A" Safety Injection N.A.
66
$18841B" Safety Injection N. A.
73 5189058*
Safety Injection N.A.
51896d# Safety Injection N. A.
SI8905L*
73 Safety Injection N.A.
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k 55 34 FP345" Fire Protection N. A.
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33 CV8368A*
RCP Seal Injection N.A.
I 33 CV8368D*
RCP Seal Injection N.A.
$3 CV83688*
RCP Seal Injection N. A.
53 CV8368C*
RCP Seal Injection N. A.
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- 11. S/G Safeties /PORVs C
77 MS013D*
Main Steam N. A.
C 77 M50140*
Main 5 team N. A.
77 MS0150*
Main Steam N.A.
77 MS0160*
Main 5 team N. A.
77 M5017D*
Main Steam N.A.
78 MS013A*
Main Steam N.A.
C 78 MS014A*
Main Steam N.A.
78 M50lbAk Main Steam N. A.
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78 MS016A*
M4in Steam N.A.
l 78 M5017A*
Main Steam N. A.
85 M5013B" Main Steam N. A.
85 M50148*
Main Steam N.A.
85 M5015B*
Main Steam N. A.
- c..'
85 MS016B*
Main Steam N. A.
85 MS017B*
Main Steam N.A.
C.
86 M5013C" Main Steam N.A.
86 M5014C' Main Steam N.A.
86 MS015C*
Main Steam N. A.
g 86 M5016C*
Main Steam N. A.
86 M5017C*
Main Steam N. A.
77 M50180*
Main Steam 20 78 MS018A" Main Steam 20 B5 M50188*
Main Steam 20 86 M5018C" Main Steam 20
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"Not subject to Type C leakage tests.
- " Proper valve operation will be demonstrated by verifying that the valve l
strokes to its required position.
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- May be opened on an intermittent basis under administrative control.
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BYRON - UNITS 1 & 2 3/4 6-24 l
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TABLE 3.6-1 CONTAINMENT ISOLATION VALVE $
l MAXIMUM PENETRATION VALVE N0.
FUNCTION 150LAT!0N TIME ($EC) 1.
Phase "A" Isolation 28 CY8100 RCP Seal Water Return 10 28 CV8112 RCP Seal Water Return 10 41 CV8152 RCS Letdown 10 41 CV8160 RCS Letdown 10 t
5 WO20A Chilled Water 50 6
5 WO56A Chilled Water 50 6
WOO 6A Chilled Water 50 8
WO208 Chilled Water 50 8
WO568 Chilled Water 50 10 W0068 Chilled Water 50 22 CC94378*
Excess Lton HX Return 10 48 CC9437A*
Excess Ltan HX Supply 10 1
34 FP010" Fire Protection 12 39 IA065 Instrument Air 15 39 IA066 Instrument Air 15 13 SG079 Hydrogen Recombiner 60 13 SG080 Hydrogen Recombiner 60 13 SG082 Hydrogen Recombiner 60 13 SG084 Hydrogen Recombiner 60 i
23 SG081 Hydrogen Recombiner 60 t
23
- G085 Hydrogen Recombiner 60 69 SG057A Hydrogen Recombiner 60 69 SG083 Hydrogen Recombiner 60 56 SA032 Service Air 4.5-
$6 SA033 Service Air 4.5 80 S0002C
- Steam Generator Blowdown
- 7. 5 80 500058 e Steam Generator Slowdown
- 3. 0 4
81 S0002D
- Steam Generator Blowdown
- 7. 5 82 SD002A
- Steam Generator Slowdown 7.5 82 50005A A Steam Generator 81owdown 3.0 83 500028 +
Steam Generator Blowdown
- 7. 5 88 50002E y.
Steam Generator Blowdown 7.5 88 SD005C +
Steam Generator Blowdown 3.0 89 SD002F v.
Steam Generator Slowdown 7.5 90 SD002G K Steam Generator Blowdown 7.5 l
90 S00050 5 Steam Generator Slowdown 3.0 91 SD002H t Steam Generator 81owdown 7.5 BRAIDWOOD - UNITS 1 & 2 3/4 6-18 m,
l TABLE 3.6-1 (Continued)
CONTAINMENT !$0LAT!0N VALV(5 MAXIMUM PENETRATION VALVE NO.
FUNCTION
!$0LATION TIM [ ($[C)
- 10. Check (Continued) 60 S!8819C*
SafetyInjection N. A.
f 60 5188190*
Safety Injection N. A.
66
$18441A*
Safety injection N.A.
66 5188418*
Safety Injection N.A.
73 5189058*
Safety' Injection N.A.
73
$18905C"_
Safety Injection N.A.
55
$18964 C b
- Safety Injection N.A.
l 34 FP345*
Fire Protection N./.
33 CV8368A*
RCP Seal Injection N.A.
33 CV83680*
RCP Seal Injection N.A.
$3 cv83688*
RCP Seal Injection N.A.
53 CV8368C" RCP Seal Injection N. A.
- 11. S/G Safeties /PORVs 77 M50130*
Main Stoas N. A.
77 MS0140" Main 5toan N.A.
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77 M50150*
Main Steam N.A.
77 MS0160*
Main 5toas N. A.
77 M5017D*
Main 5 team N.A.
78 MS013A*
Main $toas N.A.
78 M5014A" Main Steam N. A.
76 M5015A*
Main Steam N. /..
78 MS016A*
Main Steam N. A.
78 MS017A*
Main 5toam N.A.
85 MS0138*
Main 5toas N. A.
85 M50148" Main Steam N. A.
85 M50158*
Main 5toas N.A.
85 MS0168*
Main Steam N. A.
85 MS0178*
Main 5taan N.A.
86 MS013C*
Main 5toas N.A.
86 M5014C" Main 5 teas N.A.
86 M5015C" Main Steam N.A.
86 MS016C*
Main 5tean N.A.
86 MS017C*
Main Steam N.A.
77 M50180*
Main Steam 20 78 MS018A*
Main Steam 20 85 M50188*
Main Stean 20 86 MS018C*
Main Steam 20 "Not subject to Type C leakage tests.
- Proper valve operation will be demonstrated by verifying that the valve strokes to its required position.
- May be opened on an intermittent basis under administrative control.
BRAIDWOOD - UNITS 1 & 2 3/4 6-24
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EVAL 11ATION OF SIGNITICANT RAZARDS CQ2(SIDERATIONS Commonwealth Edison Byron Station has evaluated the proposed amendment and determined that it involves no significant hasards consideration. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hasards considerations if operation l
of the facility in accordance with the proposed amendment would nott 1.
Involve a significant increase in the probability or consequences of L
an accident previously evaluatedt or 2.
Create the possibility of a new or different kind of accident l
paeviously evaluatedt or 3.
Involve a significant reduction in margin of safety.
The proposed amendment makes the following changes to Technical Specification 3/4.6.3 t
1.
Deletes the requirement for type C leakage testing for valves 1/2 SD002A through H and 1/2 SD005A through D by inclusion of an "*"
after the above mentioned valves which references the note "*Not subject to Type C leakage tests."
I 2.
Deletes the inclu'sion of an "*" by the 1/2 S18968 valves. Thus, type C leakage testing requirements for the 1/2 SIB 968 valves are indicated in the Technical Specification.
l 1.
The prohahility_of an occurranct_or the contt.quange of an 4Calden kol malfunction.of_aquipment_impor_ tant.to safety as pitYinualy_tyalualad in the UfEAR is naL_ginnificantiv increastd for the reasons as follong.
l-The deletion of the requirement for type C leakage testing of the steam l
I generator blowdown system (SD) valves is not an initiating condition for any accident analysis in the UFSAR. There are two accident analyses that consider steam generator (SG) blowdown in their analysis.
In the first, for the Main Steamline Rupture accident analysis in the UFSAR Table 15.1-2, the SD blowdown valves autoclosure feature is required in the accident analysis not for the l.
mitigation, but as an assumption for the analysis. Since the SD valves will still be tested for autoclosure and stroke time when a phase A containment isolation signal is present, the above accident analysis assumption concerning SG blowdown isolation remains satisfied with the change.
In the second, for the Steam Generator Tube Rupture (SGTR) accident analysis, Table 15.6-5 lists under parameters used in the SGTR analysis the initial condition of 15 spm l
r ATTACIDENT C (CONT) blowdown per SG prior to the accident and no SG blowdowr. during the accident, j
No blowdown is the most conservative assumption for the analysis to maximise I
the potential radiological release to the environment since all the primary to secondary leakage (radiological isotopes) would remain in the ruptured SG and would not be removed by blowdown. Thus, the proposed change would have no ef f ect on this accident analysis since the most conservative assumption (no blowdown) was used in the analysis and the change would not af fect this (any leakage past the blowdown isolation valves would decrease the inventory of radiosotopes left in the ruptured steam generator that would be available for I
release).
The SG Blowdown system is not considered in the mitigation of any accident. With regard to the UFSAR Section 15.2 accident analyses for decreased heat sink,_the auxiliary feedwater system is the means of mitigation of the accidents.
Isolation of SG blowdown conserves the SG secondary side water but does not mitigate the consequence of any accident as described in l
the UFSAR. There is no increase, significant or otherwise, in the cons'equences of an accident previously t"sluated in the UFSAR.
Since the secondary side of the SG is considered a closed system meeting the requirements of NUREG 0800 6.2.4.II.6.0, the proposed change would not increase, significantly or otherwise, the probability of a leakage path to the environment. Thus, the 10CFR100 limits would not be significantly affected for any accident analysis. Technical Specification limits on primary to secondary leakage and on both primary and secondary radiation levels would continue to ensure that in the event of an accident the offsite dose limit would remain within a small iraction of the 10CFR100 limits.
In the event af a SGTA with some leakage past the SD valves, there would be no effect on the radiological release in the analysis since the most conservative assumption of no blowdown was used in the analysis. Any leakage past the blowdown valves would be into a blowdown system dvsigned to handle the liquid. The Blowdown demineralizer outlet radiation monitor would alarm if leakage occurred.
Various Auxiliary Building area radiation monitors would alarm on eleva.ted radiation levels in the Auxiliary Building in the event of leakage from the SD system piping to the Auxiliary Building. As designed, the negative pressure in the Auxiliary Building and the Charcoal Booster fans and filters would ensure that the radiation would not be released to the environment. Since any leakage would be expected to be a small amount and localized in the Auxiliary Building no adverse consequences would result. There would be no significant effect on any accident analysis.
Thus, for the above reasons, the proposed change of deletion of type C testing for the SD valves does not significantly increase the probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR.
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&IIAcamewT c (c(3(IJ The inclusion of type C testing for the $18968 valves is a change of an editorial nature and merely corrects the Technical Specification to make it consistent with the UFSAR. The SIB 968 valves have always required type C testing per 10CFR50 Appendix J, and the testing has always been done.
For this reason, the change does not significantly increase the probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR.
2.
IhtJossihilitLior an accident _nr_nalluncliun_ni_aJLiffarant_ type _than any_PIRYiqualLEYalugtsd in the UESAR is not_citattd.
The SD system is Category 1 Safety Class B piping up to and including the isolation valves, and has manual isolation valves. With respect to the accident analysis in Section 15.2 of the UFSAR where there is a decrease in the heat removal by the secondary system, SG blowdown isolation is not required to mitigate any of the accidents in the analysis. Auxiliary feedwater initiation mitigates the accidents. The amount of leakage is insignificant with respect to the total SG secondary water mass. Though the SD isolation valves do autoclose on a phase A containment isolation signal to conserve SG secondary side mass, this is not required to mitigate the effects of any accident in the UFSAR. No other accident or malfunction would be created. Thus, *he possibility for an accident or malfunction of a different type than any previously created in the UFSAR is not created.
The change to include the type C leakage test for SI8968 valves does not create the possibility for an accident or malfunction of a different typ.e than any previously analyzed, since the change is of an editorial nature and' reflects the type of testing already done since it has been required.
3.
The_ margin nf_ safety _na_delined_in_the hasis_ lor any Technical SRttilltatign is not gismificantiv reduced.
Pursuant to NUREG 0800 6.2.4.II.6.o the SG secondary is a closed system and therefore does not meet the 100FR50 Appendix J criteria for type C leakage testing. That is, no direct path would exist from containment to the outside atmosphere which might result in a radiological release to the environment and as such, satis (les its containment isolation function without type C testing requirements. Technical Specification limits on primary to secondary leakage and both primary and secondary radiation limits ensure that in the event of an accident (in particular, a SGTR), the offsite dose limits would be only a small portion of the 10CTR100 limits. The containment isolation function of the SD valves is to conserve the SG secondary 6ide mass in the event of an accident. Surveillances to verify autoclosure and stroke time ensure that the SD valves are functionally operable. The bases for containment isolation valves Technical Specification 3/4.6.3, is that "the operability of the containment isolation valves ensures that the containment atmosphere will be isolated from d
h ArrAcmaxT c (cQNT) the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment." (Technical Specifiestion 3/4.6.3 Bases p. B 3/4 6-4).
This would be satisfied with the proposed change. Thus, the margin of safety as defined in the bases for any Technical Specification is not significantly reduced.
i The change to require type C testing for the S18968 valves is of an editorial nature and does not reduce the margin of safety as defined in the basis for any Technical Specification.
Therefore, based on the above evaluation. Commonwealth Edison believes that these changes de not involve a significant hazards consideration.
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f ATTACEWNT_)
0-4 ENV110lttENIAL ASSESSMENT STATMENT APPLICABILITY REVIEW Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actionn requiring environmental assessment in accordance with 10CTR51.21. The proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CTR$1.22(c)(9) in thats 1.
The proposed amendment involves no significant hazards consideration (See Attachment C)t i
2.
There is no significant change ir the types or significant increase in the amounts of any effluents that may be released offsite, and 3.
There is no significant iceresse in individual or cumulative occupational radiation exposure.
Pursuant to 10CFR$1.22(b), no environmental assessment or environmental impact statement is required with the issuance of the proposed amendment.
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