ML20069G918

Proposed TS Section 3.7, Containment Sys

ML20069G918
Person / Time
Site:	Duane Arnold
Issue date:	05/27/1994
From:	IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:
Shared Package
ML20069G913	List: ML20069G918 NG-94-0794, Request for TS (RTS-246A) Rev to RTS-246 to License DPR-49, Revising TS Section 3.7, Containment Sys
References
NUDOCS 9406100221
Download: ML20069G918 (11)

Text

DAEC-1 Lf"' TING CONDITIONS FOR OPERATION SURVE!*

• ANCE REQUIRIMENT l 1 Primary Containment Power l

B.

Primary Containment Power Operated Isolation Valves operatec Isolation Valves 1.

Durir.g reactor power operating 1.

The primary containment isolation conditions, all primary valves surveillance shall be containment isolation valves and performed as follows:

all instrument line flow check valves shall be OPERABLE except a.

At least once per operating cycle l

as specified in 3.7.B.2.

l the OPERABLE isolation valves #

that are power operated and automatically initiated shall be tested for simulated automatic initiation and closure times.

b.

At least once per quarter 1)

All normally open power operated l

isolation valves ## reall be fully closed and reopened.

2)

With the reactor power less than 75%, trip main steam isolation valves individually and verify I

closure time.

c.

At least once per operating cycle the operability of the reactor coolant system instrument line flow check valves shall be verified.

2.

With one or more of the primary containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either s

a.

Restore the inoperable valve (s) to OPERABLE status, or b.

Isolate each a e

Pe_netrat og_gi wee c{ :

i ee* emetic i; leti n velc:

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PencfrAfions isolate.cQ l fDue to operation limitations, the Main j

• !: 1 ti:n 7:lver cierr' to satisfy Steam Line Isolation valves are exempt these vsqus.roments day a reopened on l from Subsection 4.7.B.1.a.

an intermittent basis under administrative control.

l ##Due to plant operational limitations, the Well Cooling Water Supply / Return Valves, Reactor Building Closed Cooling Water Supply / Return Valves and the I

Containment Compressor Discharge and i

Suction valves are exempt from the l requirements of subsection 4.7.B.1.b.

l or/H RTS-246 A 3.7-7

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9406100221 940527 PDR ADOCK 05000331 PDR p

DAEC-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT

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3.

If Specifications 3.7.B.1, and 1

3.7.B.2 cannot be met, an orderly shutdown shall be initiated and the reactor shall be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l 4.-

Purging a.

Containment vent / purge valves (CV-4300, CV-4301, CV-4302, CV-4303, CV-4 306, CV-4307, CV-4308, CV 4309, and CV-4310) may not be opened so as to create a flow path from the primary containment while PRIMARY CONTAINMENT INTEGRITY is required except for inerting, de-inerting, vent / purge valve testing, or pressure control.

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CAEC-1 LIMITING CONDITIONS FOR OPERATICN SURVEILLANCE REQUIR7. MENT l

E.

Drywell - Pressure Suppression l

E.

Drvwell - Pressure Suppressic,.

i tamDer Vacuum Breaxers l

Chamoer Vacuum Breaxers Six3 l

1.

J rywell - pressure l

1.

Each drywell pressure suppressio, l

spgpppsAion chamber vacuum l

chamber vacuum breaker sna11 be I

b reakerS) hall be OPERABLE and

-l verified closed at lease once per N

i L"le^seVat all times when PRIMIJtY l

7 days.

7 l

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1. rywell-pressure

'td eist^o M month,'cy6 M 2.

If one of t A

suppression chamoer vacuum drywell pressure suppression breakers is inoperable for chamber vacuum breaker through at I

opening but known to be closed, least one cycle of full travel.

restore the 2noperable vacuum Verify each position indicator breaker to 07ERABLE status within OPERABLE by observing expected 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or oe in at least HOT valve movement during the cycling SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> test.

and in COLD SHWDOWN within the following 24 houce.

I 3.

With one or more drywed 1 -

pressure suppression cha2cher vacuum breakers open, close 1.he l

open vacuum breaker (s) within 2 l

hours or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDO ithin the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. *-m o $ e ck-4.

With one of th ^;poifft16"n 3.

Once/ cycle, each drywell-pressure indicators of any drywell-suppression chamber vacuum breaker l

pressure suppression chamber shall be visually inspected to insure proper maintenance and py n hraaker inop[erablec oY[

operation.

's 3 L;,/0 E vu rw h e r @I f' PMer a cthe @ Wit indicator OPERABLE within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> l

4.

A leak test of the drywell to and at least once per 14 days suppression chamber structure thereafter or, shall be conducted once per i

operating cycle.

Verify that the vacuum breaker is l m j

closed by determining that the l

total drywell to suppression pool I

bypass area is less than 0.2 fta j

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 14 daya thereafter.

1 Otherwise be in at least HOT l

SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l

and in COLD SHUTDOWN within the i

following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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CAEC-1 LIMITING CONDIT!CNS FOR OPERATICN SURVEIll.ANCE REQUIREMENT i

l K.

Secondary containment Aute.atic l

K.

Secondary Centainment Automatic l

Isolation cameers l

Isolation campers l

1.

All secondary containment 1.

At least once per operating cycle, l

automatic isolation.

the OPERABLE isolation dampers j

valves / dampers shall be OPERABLE that are power operated and I

at all times when SECONDARY l

automatically initiated shall be l

CONTAINMENT INTEGRITY is j

tested for simulated automatic l

required.

1 initiaticn.

2.

With one or more of the secondary containment automatic isolation valves / dampers inoperable, l

maintain at least one isolation l

valve / damper OPERABLE in each L

l affected penetration that is open l

and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> either a.

Restore the inoperable valve / damper to OPERABLE status, l

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l b.

Isolate each af f ected penetration

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3.

If the above specifications cannot be met, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and suspend reactor building fuel cask and irradiated fuel movement.

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be reopened on an intermittent basis under administrative i

control.

c5/94

'RTS-2 4 6 J 3.7-1B N

-l

CAIC-1 LIMITING CONDITIONS FOR OPERATION SURVEIL

• ANCE REQUIREMENT l

L.

Standby Gas Treatment System l

L.

Standby Gas Treatment System 1.

Except as specified in 1.a Annually it shall be demonstrated l

Specifications 3.7.L.3 and 3.9.D, that pressure drop across the both trains of the standby gas combined high efficiency and tKcte @Ak, filters is less than 11 treatment system shall be 0p ater in the flow range OPERABLE at all times when SECONDARY CONTAINMENT INTEGRITY of 3600 to 4000 cfm.

is required.

b.

Annually demonstrate that the inlet heaters on each train are capable of an output of at least l

22 Kw.

c.

After each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing, demonstrate that air distribution is uniform within 20% of averaged flow per unit across HEPA filters.

d.

Once per operating cycle automatic initiation of each branch of the standby gas treatment system shall be demonstrated.

e.

Manual operability of the bypass system for filter cooling shall be demonstrated annually.

f.

System drains shall be inspected quarterly for adequate water level in loop seals.

g.

Each bed will be visually inspected in conjunction with the sampling in Specification l

3.7.L.2.b to assure that no flow blockage has occurred.

2.a The results of the inplace cold 2.a The tests and sample analysis of DOP and halogenated hydrocarbon l

Specification 3.7.L.2 shall be tests in the flow range of 3600-performed initially and then 4000 cfm on HEPA filters and annually for standby service or charcoal adsorber banks shall after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system show 2 99.9% DOP removal and 2 operation and following 99.9% halogenated hydrocarbon significant painting, fire or removal.

chemical release in any ventilation zone communicating with the system.

b.

The results of laboratory carbon b.

Cold DOP testing shall be sample analysis shall show < l.0%

performed after each complete or penetration of radioactive methyl partial replacement of the HEPA iodide at 70%

R.H.,

150*F, 40 1 4 filter bank or after any FPM face velocity with an inlet structural maintenance on the concentration of 0.5 to 1.5 mg/m system housing.

3 inlet concentration methyl Halogenated hydrocarbon testing iodide.

c.

shall be performed after each c.

Fans shall be shown to be capable complete or partial replacement of of operation from 1800 cfm to the the charcoal adsorber bank or flow range of 3600-4000 cfm.

after any structural maintenance on the system housing.

OSI94 4Gf+2-i RTS-246A 3.7-19 g

CAEC-1 l The ability to mitigate an event that causes a containment depressurizatten is l threatened, however, if both vacuum breakers in at least one vacuum breaker l penetration are not OPERABLE.

Therefore, the inoperable vacuum breaker must l be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on the fact that the l leak-tight primary containment boundary is being maintained.

l With one valve of a vacuum breaker assembly open, the leak-tight primary l containment boundary may be threatened. Therefore, it must be confirmed that l at least one vacuum breaker in each affected line is closed.

Failure to i verify a closed vacuum breaker would imply that a breach in primary l containment exists.

The inoperable vacuum breakers must be restored to l OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The 72-hour Completion Time takes into l account the redundancy capability afforded by the remaining breakers, the fact l that the OPERABLE breaker in each of the linas is closed, and the low l probability of an event occurring that would require the vacuum breakers to be i operable during this period.

l 3.7.E and 4.7.E Bases l Drywell - Pressure Suppression Chamber Vacuum Breakers The capacity of the 7 drywell vacuum relief valves are sized to limit the pressure differential between the suppression chamber and drywell during post-accident drywell cooling operations to well under the design limit of 2 psi.

They are sized on the basis of the Bodega Bay pressure suppression system tests.

The ASME Boiler and Pressure vessel Code,Section III, subsection B, for this vessel allows a 2 psi differential; therefore, with one vacuum relief valve secured in the closed position and 6 operable valves, containment integrity is not impaired.

rf%

l With one of the required reakers inoperable for opening but known to I be closed (e.g.,

tne vacuum braaker is not open, and may be stuck closed or l not within its opening setpoint limit, such that it would not function as

,-m ~ r W Y R) l deptgned during an event that depressurized the drywell),

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l RTS-246A 3.7-28

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a tion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restor vacuum breakerjf to s

~-

j OPERABLE status.

The 72-hour Completion Time takes into account e redundant l capability afforded by the remaining breakers, reasonable ttme for the I repairs, and the low probability of an event occurring during this period l requiring the vacuum breakers to function.

l An open vacuum breaker allows communication between the drywell and j suppression chamber airspace, and, as a result, there is the potential for l suppression chamber overpressurization due to this bypass leakage if a LOCA l were to occur.

Therefore, the open vacuum breaker must be closed.

The 2-hour l Completion Time is based on the time required to complete the alternate method l of verifying that the vacuum breakers are closed, and the low probability of a l DBA occurring during this period.

l 3.7.F and 4.7.F Bases l Main Steam Isolation Valve Leakage Control System (MSIV-LCS)

The MSIV-LCS system is provided to minimize the fission products which could bypass the standby gas treatment system after a LOCA.

It in designed to be manually initiated after it has been determined that a LOCA has occurred and that the pressure between the MSIV's has decayed to less than 35 psig.

The System is also inhibited from operating unless the inboard MSIV associated with the MSIV-LCS subsystem is closed and the reactor vessel pressure has decayed to less than 35 psig.

I Checking the operability of the various components of the MSIV-LCS system monthly, and the motor-operated valves once every 3 months, assures that the l

MSIV-LCS system will be available in the remote possibility of a LOCA.

Performance of a capacity test of the blowers and initiation of the entire system once per operating cycle assures that the MSIV-LCS system meets its design criteria.

The testing frequency of the motor-operated valves is based on Section XI of the ASME Code.

Allowance of thirty days to return a MSIV-LCS l

l os'I R 4 l

l RTS-246A 3.7-29

-00/02-

"lRE C-1 1

3.7.K and 4.7.K BASES C

l Secondary Containment Autom4 tic _Isolat;.on Damperjsse;-

^F 6 nel,A6n Mafrirnarst is o(a4106 Valvc.5 /cbt

] The function of th mornation W M 6ETier accice h mitigatic

~

l systems, is to limit fission-product release during the following postulated l Design Basis Accidents such that offsite radiation exposures are maintained l within the requirements of 10 CFR 100 or the NRC staff-approved licensing i basis.

Secondary containment isolation within the time linits specified for l those isolation valves designed to close automatically ensures that fission l products that escape from primary containment following a DBA, or which are l released during certain operations when primary containment is not required to l be OPERABLE or take place outside primary containment, are maintained within l applicable limits.

A controlled list of secondary containment automatic l isolation dampers is located in the plant Administrative Control Procedures.

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con &QnmentIEolChon Vd.IVes / McAW)p.gfs }

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l The OPERABILITY requirements for 4CUJ.sIfEelp ensure that adequate secondary

+H l containment leak tightness is maintained during and after an accident by l minimizing potential paths to the environment.

These isolation devices j consist of either passive devices or active (automatic) devices.

Locked-l closed manual valves, deactivated automatic valves secured in their closed l position, blind flanges, and closed systems are considered passive devices.

l Two barriers in series are provided for each penetration so that no single l credible failure or malfunction of an active component can result in a loss of l isolation (and possibly loss of secondary containment OPERABILITY).

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,,.. y l With one or more

',.se4 inoperable, at least one isolation valve must be v

l verified to be OPERABLE in each affected open penetration.

This action may be l satisfied by examining logs or other information to determine whether the l valve is out of service for maintenance or o,ther easons.

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either the inoperable l In tpe_ event,,that one or more p~ lare inoperable, W /w omp er;)

l valve'40st*We' restored to OPERABLE status or the affacted penetration must be ss l isolated.

The method of isolation must include the use of at least ene 05/ 9 l RTS-246h 3.7-37 C/M

f DAEC-1 l 1sblation barrier tnat cannot be adversely affected by a single active da N

p h @logicm V CL v e h O Q l failure.

Isolation bar jerg 4P 4 y s

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l deactivated automatic a e osee manualtva v pee p

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.. w) ww Demonstrating the isolation capabilities of eacn power-operated and automatic i

! -Gei4-is required to demonstrate ITY.

The simulated automatic Eh l initiation ensures that thatvalve Tsolate as assumed in the safety l analyses. The frequency of this SR is in accordance with the Inservice l Testing Program.

l 3.7.L and 4.7.L BASES

[ Standby cas Treatment System The standby gas treatment system is designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions, with a minimum release of radioactive materials from the reactor building to the environs.

Both standby gas treatment fane are designed to automatically cuart upon containment isolation and to maintain the reactor building pressure at approximately a negative 1/4-inch water gauge pressure; all leakage should be in-leakage. Only one of the two standby gas treatment systems is needed to cleanup the reactor building atmosphere upon containment isolation.

If one system is made or found to be inoperable during reactor operation or core alterations, there is no immediate threat to the containment l

system performance.

Thus, reactor or refueling operation (s) may continue while repairs are being mada, provided the requirements of Specifications i

3.7.L.3 and 3,9.D, respectively, are met.

If neither circuit is operable, the plant is brought to a condition where the standby gas treatment system is not required.

High efficiency particulate absolute (HEPA) filters are installed before and after the charcoal adsorbers to minimize potential release of particulates to the environment and to prevent clogging of the iodine adsorbers.

The charcoal adsorbers are installed to reduce the potential release of es/qu l ars-24sA 3.7-as c:/ :

DAEC-1 radiciodine to the environment.

The in-place test results should indicate a l system leak tightness of 5 0.1 percent bypass leakage for the charcoal adsorbers and a HEPA efficiency of at least 99.9 percent removal of DOP particulates.

The laboratory carbon sample test results should indicate a I radioactive methyl iodide removal efficiency of at least 99% for expected accident conditions.

If the efficiencies of the HEPA filters and charcoal adsorbers are as specified, the resulting doses will be less than the 10 CFR 100 guidelines for the accidents analyzed, as the Updated FSAR Section 15.6.6 for the loss-of-coolant accident shows compliance with 10 CFR 100 guidelines with an assumed efficiency of 99% for the adsorber.

Operation of the fans significantly different from the design flow envelope will change the removal efficiency of the HEPA filters and charcoal adsorbers.

l l

A pressure drop test across the combined HEPA filters and charcoal adsorbers will indicate that the filters and adsorbera_are_ not, clogged b excessive

~ j hh d '

amounts of foreign matter.

Heater capabilityg pressure drop and cir di;tribution should be determined annually to show system performance capability. Smavd demons +r@'on d n*r c$isfri b uh'a n is not re.guic ed. C.6

=.s O 3

bc c 9 ected to o c.c.u r' dfef c hoq c

• Pt. ("ad e-the. flow clistribdort Wo G Her he> u sing rcthe thqn o n 4 -tirn e-de-pan d =M bcts i s.

h> &. Cl&ces or The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbon refrigerant shall be performed in accordance with USAEC Report DP-1082.

Iodine removat efficiency tests shall follow RDT Standard M-16-lT.

(The design of the SGTS syatem allows the removal of charcoal samples from the bed directly through the use of a grain thief.)

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed.

If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 4.7-1. Tests of the EEPA filters with DOP aerosol shall be performed in accordance to ANSI N101.1-1972.

Any HEPA filters found defective shall be replaced.

The replacemer.t HEPA filters should be steel cased and designed to military specifications MIL-F-51068C and MIL-F-51079A.

The HEPA c5/99 l RTS-246k 3.7-39 04/9f-

/

1 1

i BLIND CARBON COPY LIST FOR NG-94-0794 Rich Anderson M. McDermott T.

Barada W.

Render P.

Bessette OC Engineer J.

Bjorseth K.

Peveler P. Jakoubek (Commitment R.

Potts Control)

W.

Rose (Safety N.

Chapman (SERCH)

Committee)

CIPCO K.

Shea (NB&H)

Corn Belt S.

Swalls GDS Associates, Inc.

Training Center J.

Easton G.

Van Middlesworth Excel D. Wilson R.

Hannen P.

Wojtkiewicz J.

Kinsey K.

Young

SUBJECT:

Request for Technical Specification (RTS-246A):

" Revision to RTS-246"

REFERENCE:

N/A FILE:

A-117, T-23a t

p I