ML20046A231

Proposed Tech Specs Re Containment Isolation Valve Table

ML20046A231
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/22/1993
From:	ENTERGY OPERATIONS, INC.
To:
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ML20046A225	List: ML20046A224 ML20046A231
References
NUDOCS 9307270123
Download: ML20046A231 (18)

Text

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i ATTACHMENT c

E 2CAN079302 PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN THE MATTER OF AMENDING -

LICENSE NO. NPF-6 ENTERGY OPERATIONS, INC.

ARK.ANSAS NUCLEAR ONE, UNIT TWO DOCKET NO. 50-368 9307270123 930722 8 [i R_ ADDCK 0500 ,

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Attachment to 2CAN079302 Page 2 of 7 DESCRIPTION OF PROPOSED CII ANGES Table 3.6-1 of ANO-2 Technical Specifications (TS) lists containment isolation valves and their respective isolation time requirements. The proposed change is a line-item TS improvement to remove Table 3.6-1 from the TS in accordance with the guidance provided in Generic Letter 91-08. As a part of this request, ANO commits to maintain a table of containment isolation valves in station procedures.

The proposed change:

. Removes Table 3.6-1 and replaces references to the list of containment isolation valves with explicit descriptions of the affected valves.

. Adds a footnote to Limiting Conditions for Operation (LCO) 3.6.3.1 to allow locked or sealed closed valves to be opened under administrative controls. Specifications that refer to Table 3.6-1 for a list of containment isolation valves that may be opened under administrative controls have been revised to reference Specification 3.6.3.1.

. Removes the footnote to Table 3.6-1 that identifies those valves that are not required to satisfy the requirements of" Type C" leakage tests.

. Removes valve isolation time requirements from LCO 3.6.3.1.

. Adds to Containment Systems Bases, a description of the requirements for " administrative control" and a reference to the new list of containment isolation valves in Procedure 2203.005.

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. Renumbers pages following Table 3.6-1 and corrects the Index. l Table 3.6-1 is deleted by removing pages 3/4 6-18,3/4 6-19,3/4 6-20 and 3/4 6-21. The  ;

change also revises those Specifications that refer to Table 3.61 for a listing of containment isolation valves. The revised Specifications explicitly describe the affected valves. References to Table 3.6-1 in the LCO and Action Statement of TS 3.6.3.1 and in  ;

SR 4.6.3.1.1,4.6.3.1.2 and 4.6.3.1.4, have been replaced with explicit descriptions of the affected valves.

A footnote is added to LCO 3.6.3.1 to allow locked or sealed closed containment isolation valves to be opened under administrative controls. Table 3.6-1 contains a footnote that identifies valves permitted to be opened under administrative control. This footnote is deleted with Table 3.61. References to Table 3.6-1 and the footnote on administrative controls are changed to reference the new footnote in Specification 3.6.3.1. The definition of" Containment Integrity" in Specification 1.8 and Specification 4.6.1.1.a refer to Table

3.6-1 for a listing of the valves that may be open under administrative controls. The

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Attachment to 2CAN079302 Page 3 of 7 proposed change replaces those references with an exception for " valves that are open under administrative control as permitted by Specification 3.6.3.1."

i Containment isolation valves are subject to the requirements of" Type C" testing described l in Appendix J to 10CFR Part 50. This change deletes the footnote to Table 3.6-1 that identifies the containment isolation valves that are exempt from those requirements. j l

Currently, Specification 3.6.3.1 requires the containment isolation valves meet the isolation times listed in Table 3.6-1. The proposed change deletes the isolation times and the LCO requirement to meet them. The change retains the requirement that "Each containment isolation valve shall be OPERABLE."

To preserve continuity, pages 3/4 6-22,3/4 6-23 and 3/4 6-24 have been renumbered 3/4 6-19,3/4 6-20 and 3/4 6-21 respectively. The Index has been updated accordingly. An additional administrative change has been made to correct a grammatical error in Specification 1.8.1 by replacing " condition" with " conditions."

HACKGROUND Generic Letter 9 l-08, Removal of Component Listsfrom Technical Specifications, provides guidance to licensees pursuing amendments to remove component lists from Technical Specifications. In accordance with the provided guidance, component lists removed from Technical Specifications must be relocated in plant procedures that are  !

subject to the change control provisions in the Administrative Controls Section of Technical Specifications. These changes allow component lists to be updated without license amendments. Technical Specification references to component lists are to be  ;

replaced with general statements that describe the types of components to which the requirements apply. Since any change to procedural component lists will be subject to the provisions of Section 50.59 of Title 10 of the Code of Federal Regulations, adequate controb will exist to ensure that these components satisfy the applicable Technical Specification requirements.

The proposed change removes Table 3.6-1 in accordance with Generic Letter 91-08; Specifications that refer to Table 3.6-1 have been revised to reference the applicable valves by function. Enclosure 2 to Generic Letter 91-08 provides the changes necessary to remove Table 3.6-1 from the Standard Technical Specifications. A's described, these l changes allow the Table to be removed without altering exicting Technical Specification requirements or those components to which they apply. The proposed change complies with the guidance provided for the affected sections.

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m Attachment to 2CAN079302 i Page 4 of 7 DISCUSSION OF CIIANGES i l

Table 3.6-1 is referenced in the LCO and Action Statements of TS 3.6.3.1 and in Surveillance Requirements 4.6.3.1.1,4.6.3.1.2 and 4.6.3.1.4. These Specifications refer to Table 3.6-1 for a listing of containment isolation valves. The proposed changes replace these references with explicit descriptions of the components to which the TS requirement.; apply. A new containment isolation valve list will be added to Procedure 2203.005, Loss of Containment Integrity. The new list will be subject to the Administrative Controls ofTechnical Specification Section 6 and 10CFR 50.59. As discussed in GL 91-08, removing Table 3.6-1 from TS and replacing associated references with explicit descriptions of affected components does not relax the TS requirements.

With the proposed changes, these specifications apply to all valves classified as containment isolation valves by the plant licensing basis.

Table 3.6-1 includes a footnote that allows specified valves to be opened on an intermittent basis under administrative controls. The proposed change deletes this note and adds a note to the TS 3.6.3.1 that allows all valves locked or sealed closed consistent with the design requirements of Genera! Design Criteria 55,56, and 57 of Appendix A to 10CFR Part 50 to be opened during plant operation. Currently TS 1.8 and 4.6.1.1.a refer to Table 3.6-1 for a listing of the valves that may be opened under administrative controls.

As a result of this change, TS 1.8.1 and 4.6.1.1.a will reference the new footnote in TS 3.6.3.1. The stafThas reviewed this change and concludes, in Generic Letter 91-08, that it is an acceptable alternative to identifying specific valves that may be opened under administrative control.

The footnote to Table 3.6-1 identifies valves that are not subject to 10CFR Appendix J requirements for " Type C" leak testing. In Generic Letter 91-08, the NRC concluded that the deletion of this note does not alter TS requirements.

The inservice testing requirements referenced by TS 4.0.5 include verification of valve -

stroke times for containment isolation valves. Removal of the duplicate requirement from LCO 3.6.3.1 and Table 3.6-1 does not relax TS requirements to verify containment isolation valve stroke times.

The Containment Isolation System Bases is amended to include a reference to the new containment isolation valve table in procedure 2203.005 and the considerations that  ;

constitute an acceptable administrative control for opening locked or scaled closed containment isolation valves. These additions to the Bases do not alter TS requirements and are implemented as discussed in GL 91-08.

Renumbering pages: 3/4 6-22,3/4 6-23 and 3/4 6-24 and updating the Index are administrative changes to remove blank pages created by deleting Table 3.6-1. . An additional administrative change is made to correct a gramatical error in TS 1.8.1 by rephemg " condition" with " conditions." This change does not alter TS requirements.

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Attachment to 2CAN079302 Page 5 of 7 DETERMINATION OF NO SIGNIFICANT IIAZARDS CONSIDERATION I

An evaluation of the proposed change has been performed in accordance with 10CFR50.91(a)(1) regarding no significant hazards considerations using the standards in 10CFR50.92(c). A discussion of these standards as they relate to this amendment request follows.

Criterion 1- Does Not Involve a Significant Increase in the Probability or Consequence of an Accident Previously Evaluated.

Removal ofTable 3.6-1 and replacement of associated references with explicit descriptions of affected components ensures that the TS requirements apply to all valves classified as containment isolation valves by the plant licensing basis. Since the existing TS operability and surveillance requirements, and the components to which they apply are not reduced, this change does nql significantly increase she probability or consequence of any previously analyzed accident.

The footnote added to TS 3.6.3.1 allows all valves with the locked or sealed closed feature to be opened under administrative controls. The existing note to Table 3.6-1 identifies specif:c valves that may be opened under administrative controls. This change allows all locked or scaled closed containment isolation valves to be opened under administrative controls to ensure that the afTected component will perform its design function if necessary. These valves are not accident initiating components and do not increase the probability of an accident previously evaluated. Since the imposed operability restrictions ensure that these valves will be closed in the event of an accident, this change does nnt significantly increase the probability or consequence of any previously analyzed accident.

Since deletion of the footnote identifying valves not subject to " Type C" testing, does not alter TS operability or surveillance requirements, this change does nql significantly increase the probability or consequence of any previously analyzed accident.

The valve isolation time requirements in TS 3.6.3.1 and Table 3.6-1 are redundant to the inservice testing required by TS 4.0.5 to verify stroke times of containment isolation valves. Since the TS 4.0.5 requirements to verify stroke times are unafTected, this change l

does nel significantly increase the probability or consequence of any previously analyzed j accident. I The changes to Renumber pages: 3/4 6-22,3/4 6-23 and 3/4 6-24 and to correct the grammatical error in TS 1.8.1 do not alter TS requirements and are administrative in nature. Since these changes are administrative in nature they do not significantly increase the probability or consequence of any previously analyzed accident.  !

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. 2CAN079302 Page 6 of 7 The Bases change clarifies the administrative controls required to open locked or sealed closed valves and references the procedure.in which the new containment isolation valve l table Wil be located. Since this change does not affect reactor operations or accident analyse. nid has no radiological consequences, this change does pm significantly increase the probability or consequence of any previously analyzed accident.

Based on the discussions presented above, Entergy Operations has determined that these changes do pm significantly increase the probability or consequence of any previously analyzed accident.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident ,

from Any Previously Evaluated.

The deletion of Table 3.6-1 and its associated references does not alter the operability or surveillance requirements of ANO-2 TS. Since the duign, configuration, and method of operation of the plant are not affected, this change does nm create the possibility of a new or differert kind of accident from any previously evaluated.

Since the footnote added to TS 3.6.3.1 does not establish a potential new accident precursor, this change does pm create the possibility of a new or different kind of accident from any previously evaluated.  ;

Deletion of the isolation time requirements ic TS 3.6.3.1 snd Table 3.6-1 does not change the design, conCguration or method of operation of the plant. This change does not alter the TS requirements for verifying containment isolation valve stroke times. Since the requirements are unaltered, this change does pg create the possibilhy of a new or different kind of accident from any previously evaluated.

The changes to Renumbei pages 3/4 6-22,3/4 6-23 and 3/4 6-24, to update the Index, and to correct the grammatical error in TS 1.8.1 do not alter TS requirements and are administrative in nature. Since these change are administrative in nature they do pm create the possibility of a new or different kind of accident from any previously evaluated.

The proposed Bases changes clarify the TS requirements. These changes do not introduce any new mode of plant operation and therefore, do pm create the possibility of a new or different kind of accident from any previously evaluated. ,

Based on the discussions presented above, Entergy Operations has determined that these changes do pm create the possibility of a new or different kind of accident from any previously evaluated.

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. Criterion 3 - Does Not Involve a Significant Reduction in a Margin of Safety. l Since the deletion of Table 3.6-1 and its associated references does not reduce existing TS operability and surveillance requirements, this change does nqt involve a significant ,

redaction in a margin of safety. l i

Current TS allow the use of administrative controls as provisional measures to be taken I while opening specific locked or sealed closed valves. This change extends the use of I these controls to similar valves. Since the administrative controls required when these i valves are opened,' emure that the valve will be closed in the event of an accident, this change does nat involve a significant reduction in a margin of safety. The staff has reviewed this change and concludes in GL 91-08 that it is an acceptable alternative to identifying specific valves that may be opened under administrative controls. ~

Since deletion of the footnote to Table 3.6-1, identifying valves not su' Nct to " Type C" .

testing, and deletion of the isolation time requirements in TS 3.6.3.1 and Table 3.6-1 do not reduce existing operability or surveillance requirements, this change does nqt involve a ' i significant reduction in a margin of safety. l The administrative changes to Renumber pages: 3/4 6-22,3/4 6-23 and 3/4 6-24, to update the Index, and to correct the grammati cal error in TS 1.8.1 do not alter TS requirements. Since these change are administrative in nature they do aqiinvolve a significant reduction in a margin of safety.

The proposed Bases changes clarify the TS requirements. Since these changes do not affect a safety limit, an LCO, or a surw Dnce requirement, this change does nat involve a significant reduction in a margin of s.r.

Based on the discussions presented above, Entergy Operations has determined that these changes do no_1 involve a significant reduction in a margin of safety.

Therefore, based upon the reasoning presented above and the previous discussion of the )

amendment request, Entergy Operations has determined that the requested changes do att 1 involve a significant hazards consideration. l I

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-i PROPOSED TECH'N' CAL SPECIFICATION CHANGES .

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. INDEX-A LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 'i

'I SECTION PAGE 'l 3/4.5.2 ECCS~ SUBSYSTEMS - T avg h 300*F....................... 3/4 5-3 3/4 5.3 - ECCS SUBSYSTEMS - T avg 5 300*F......... ............. 3/4 5-6 3/4.5.4 REFUELING ~ WATER TANK,................................. 3/4 5-7 a

-3/4.6 CONTAINMENT SYSTEMS .

~3/4.6.1 PRIMARY CONTAINMENT 7 Containment. Integrity.. ............................. 3/4 6-1. .

Containment Leakage..... . . ............. ........... 3/4 6-2 .

Containment Air Locks............... . . . . . . ...... 3/4 6-4  ;

Internal Pressure. Air Temperature and .

Relative Humidity........ -

3/4 6-6 ,

1 Containment Structural Integrity. . . . . . . . . , . . . ..... . 3/4 6-8 Containment Ventilation System....... . . . . . . . . . . . . . . . 3/4 6-9a  :

~3/4.6.2 - DEPRESSURIZATION AND COOLING SYSTEMS r!

Containment Spray System...... ....... .. ... ...... 3/4.6-10 a Sodium Hydroxide Addition System.. .. . . . . . ... . . 3/4'6-12 '

Containment Cooling System... . . . . . . . . . . . . . ....... 3/4 6-14 3/4.6.3 - CONTAINMENT ISOLATION VALVES..... . . . . . . . . . . . . . . ... 3/4 6 i 3/4.6.4 COMBUSTIBLE GAS CONTROL Hydrogen Analyzers.... ............... . ......... .. 3/4 6-18 Electric Hydrogen Recombiners - W.................... 3/4 6-19 Containment Reci rculation System . . . . . 4 . . . . . . ....... 3/4 6-20 P

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ARKANSAS - UNIT 2 VII Amendment No.I60- [

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09 DEFINITIONS REPORTABLE EVENT-

.1.7 -A REPORTABLE EVENT shall be any of'those conditions specified in Section:50.73 to 10CFR Part 50.

w i CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:

1.8.1 All penetrations required to be closed during-accident conditions are either: l

a. Capable of being closed by an 0PERABLE containment automatic-isolation valve system, or ,

b. Closed by manual valves, blind flanges, or deactivated ,

automatic valves secured in their closed positions, except for valves that are open under administrative' control.

as permitted by Specification 3.6.3.1.

1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each airlock is OPERABLE pursuant to Specification -

3.6.1.3, 4 1.8.4 The containment leakage rates are within'the-limits of Specification 3.6,1.2, and 1.8.5, The sealing mechanism associated with ea'ch _

penetration (e.g., welds, bellows or 0 rings) .is'0PERABLE CHANNEL CAllBRATION

'1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the

, channel output such that it responds with the necessary range and accuracy-to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall1 include the CHANNEL FUNCTIONAL TEST. j The CHANNEL' CALIBRATION may be performed by any series of sequential, '

overlapping or total- channel steps, such that the entire channel is' calibrated.

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[ ARKANSAS'-LUNIT2. 1-2 Amendment Noi:14 \lI  ;

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S 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY-CONTAINMENT

^ l CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION  ;

3.6,1.1 Primary' CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY. restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY with 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.

SURVEILLANCE REOUIREMENTS 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that all penetrations

• not capable of being closed by OPERABLE containment automatic '

isolation valves and required to be closed during accident conditions are' closed by valves, biind flanges, or deactivated automatic valves' secured in their positions, except for valves that are open under administrative control as' permitted by Specification 3.6.3.1.  :!

b. By verifying that each containment ait lock is OPERABLE per '

Specification 3.6.1.3.

C. After each closing of the equipment hatch, by leak rate testing the equipment hatch seals with gas at Pa (54 psig) and verifying that when the measured leakage rate for these seals is added to the leakage rates determined pursuant to Specification 4.6.1.2.d for all other Type B and C penetrations, the combined leakage rate is 5 0.60 La

• Except valves, blind flanges, and deactivated automatic valves which are .

located inside the containment and are locked. sealed, or otherwise secured in the. closed position. These penetrations shall be verified- p closed during each COLD SHUTDOWN except that such verification need nnt ,j be performed more often than once per 92 days. j

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' ARKANSAS - UNIT 2' 3/4 6-1 Amendment No'

- CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT' ISOLATION VALVES l

- LIMITING CONDITION OF OPERATION f

3.6.3.1 Each containmrnt isolation valve shall be OPERABLE.* ' l, APPLICABILITY: MODES 1, 2, 3 and 4.

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- ACTION:

With one or more isolation valve (s) i noperable, maintain at least one l l1 1 solation valve OPERABLE in each affected penetration that is open and i either:

a. Restore the inoperable valve (s) to OPERABLE status wit'ein 4 ,

hours, 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  :

q position, or

c. Isolate the 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. Benin at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> andtin COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. '

SURVEILLANCE REOUIREMENTS 4.6.3.1.1 Each containment isolation. valve shall be demonstrated OPERABLE prior l to returning the valve- to service af ter maintenance, repair or replacement work is ,

performed.on the valve or its associated actuator, control or power circuit -by.

-performance of a cycling test and verification of isolation time.

• Locked or sealed closed valves may be opened on an-intermittent basis .under administrative control.

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ARKANSAS 9 UNIT.2 3/4 6-16: Amendment No. 124,134l l. -

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.l CONTAINMENT SYSTEMS-SURVEILLANCE REQUIREMENTS (Continued) 4 6.3.1.2 Each containment isolation valve shall be demonstrated OPERABLE - l during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by.

verifying that on a contairment isolation test signal, each isolation valve actuates to its isolation position. ,

4.6.3.1.3 The isolation time of each power' operated or automatic containment-isolation valve shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

4.6.3.1.4 Prior to. exceeding conditions which require establishment of.

reactor building. integrity per TS 3.6.1.1, the leak rate of the contain-ment purge supply and-exhaust isolation valves shall be verified to be within j acceptable limits per.TS 4.6.1.2, unless the test has been successfully completed within the last three months.

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ARKANSAS - UNIT 2 3/4 6-17 Amendment No. 44. l l 1

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i O CONTAINMENT SYSTEMS 3/4.6.4 _C_0[tBUSTIBLE-GAS CONTROL

' HYDR 0 GEN ANALYIERS LIMITING CCNCITION F0" 0_PERAT10N i

3.6.4.1 Two independent coc* unment hydrogen analyzers shall be OPERABLE.

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APPLICABILITY: MODES 1 and 2.

l ACTION:

With one hydrogen analyzer inoperable, restore the inoperable analyzer to '

OPERABLE states within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. '

SURVEltLANCE REQUIREMENTS 4.6.4.1 Each hydrogen analyzer shall be demonst ated OPERABLE at least ,

once per 92 days on a STAGGERED TEST BASIS by performing a CHANNEL-CALIBRATION using sample gases containing:

a. Zero volume percent hydrogen, balance nitrogen, and

b. Four volume percent (nominal) hydrogen, balance nitrogen.

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l ARKANSAS . UNIT 2 3/4 6-18 Amendment.No. l

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CONTAINMENT $YSTFMS i

ELECTRIC HYDR 0 GEN RECOMBINERS W LIMITING CONDITION FOR OPERATION 3.6,4.2 Two indepenaent containment hydrogen recombiner systems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTION:

With one hydrogen recombiner system inopersble, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY -

within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEllLANCE REOUIREMENTS 4.6.4.2 Each hydrogen recombiner system shall be demonstrated OPERABLE:

a. At least'once per'6 months by verifying during a recombiner ,

system functional test that the minimum heater' sheath temper-  ;

ature increases to 2 700*F within 90 minutes and is ' maintained i for at least 2. hours. ';

b. At least once per 18 months by: .1

1. Performing a CHANNEL CALIBRATION of all recombiner instru- 1 mentation and control circuits. ,

2. Verifying through a visual examination that there is no evidence of abnormal conditions within the recombiners *

(i.e., loose wiring or structural connections, deposits of foreign materials, etc.).

3. Verifying during a recombiner system functional test that ,

the heater sheath temperature increased to 21200*F  !

within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and is maintained for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, i 4.

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Verifying the integrity of the heater electrical circuits  :

by performing a continuity and resistance to ground test  ;

following the above required functional test. The resist- l ance to ground for any heater' phase shall be 2 10,000 ohms. -!

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'L LARKA'NSAS UNIT 2 3/4 6-19 Amendment ik). -l'

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CONTAINMENT SYSTEMS ICONTAINMENT RECIRCULATION SYSTEM LIMITING CONDITION FOR OPERATION  !

l 3.6.4.3 At least two independent. containment recirculation fans shall be OPERABLE. l APPLICABILITY: MODES 1 and 2.

ACTION:

With only one containment recirculation fan OPERABLE, restore at least two independent fans to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REUUIREMENTS

4.6.4.3 Each of the above required containment recirculation fans shall-L be demonstrated OPERABLE

a. At least once per 92 days on a STAGGERED TEST BASIS by:

1. Verifying that the fan can be started on operator action in the control room, and

2. Verifying that the-fan operates for at least 15 minutes.

b. At least once per 18 months by verifying a flow rate of at least 4500 cfm per fan.

ARKANSAS UNIT 2 3/4 6-20 Amendment.No. 3 lI

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CONTAINMENT SYSTEMS BASES 1

.The containment cooling' system and the containment spray system are '

redundant to each other in providing post accident cooling of the l containment atmosphere. As a result of this redundsncy'in. cooling- l capability, the allowable out-of-service time requirements'for the a containment cooling system have'been appropriately adjusted. However, the-allowable out of service time requirements- for. the containment spray system

'have been maintained consistent with that assigned other. inoperable ESF

/ equipment since the containment spray system also provides-a mechanism for removing Iodine from the containment atmosphere.-

In addition of a biocide to the service water system is performedi during containment cooler surveillance to prevent buildup of Asian clams >

in the coolers when service water is pumped through the cooling' coils.

This is performed when service water temperature is between 60* F and 80a F-since in this water temperature range Asian clams can spawn and produce larva which could pass through service water system strainers.

3/4.6.3 CONTAINMENT ISOLATION VALVES n

The OPERABILITY of the containment isolation volves-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 pressurization of the containment. Containment; isolation I within the time limits specified ensures that the release of radioactive material to 'the environment will be consistent with the' assumptions used in the analyses for a LOCA. The containment isolation valves are listed in Procedure 2203.005. l The opening of locked or sealed closed manua7 and deactivated automatic containment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator.  ;

who is in constant communication with control room, at the valve controls,  ;

(2) instructing the operator to close'these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside containment. :i 3/4.6.4 COMBUSTIBLE GAS CONTROL The OPERABILITY of the equipment and systems required for the  :

detection and control of hydrogen gas ensures that this' equipment will be available to maintain the hydrogen-concentration within containment below i its flammable. limit during post LOCA conditions. Either recombiner unit is capable of controllingfthe expected hydrogen generation associated with 1)-

' zirconium water reactions. 2) radiolytic decomposition of' water, and 3) corrosion of metal within containment'. These hydrogen' control systems are .

Lconsistent with the~ recommendations of Regulatory Guide 1.7 " Control lof.  ;!

Combustible Gas Concentrations in' Containment Following. a LOCA". March .

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-1971.. R l

A.RKdNSdSa ' UNIT 2 B 3/4 6-4 Amendment No. 46,'4051 1

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CONTAINMENT SYSTEMS

~ BASES The containment recirculation units are provided to ensure adequate mixing of the containment atmosphere following a LOCA. This mixing action vill prevent localized accumulations of hydrogen from exceeding the flammable limit. .

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, ARKANSAS --UNIT 2 -B.3/4 6-5

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