ML20085L041

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Proposed Tech Specs Re Deletion of Schedular Requirements for Type a Testing
ML20085L041
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 06/19/1995
From:
SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20085L040 List:
References
NUDOCS 9506280257
Download: ML20085L041 (10)
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Text

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e CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2. Containment leakage rates shall be limited to:

a. An overallintegrated leakage rate of:
1. Less than or equal to La,0.20 percent by weight of the contamment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at Pa,53.5 psig, or f
2. Less than or equal to Lt ,0.10 percent by weight of the contamment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a reduced pressure of Pt ,26.8 pstg. g '
b. A combined lea k a ce rate ofless than 0.60 La for all penetrations and valves subject to Type B and C tests, when pressurized to Pa.

APPLICABILITY: MODES 1,2,3 and 4.

ACTION:

With either t a) the measured overallintegrated contamment leakage rate exceeding 0.75 L, or 0.75 Lt , as applicable. or tb) with the measured combined  !

leakage rate for all penetrations and valves subject to Types B and C tests ,

exceeding 0.60 La, restore the overallintegrated leakage rate to less than or equal to 0.75 La or less than or equal to 0.75 Lt , as applicable, and the combined leakage rate for all penetrations subject to Type B and C tests to less than 0.60 La prior to increasing the Reactor Coolant System temperature above 200*F.

SURVEILLANCE REQLIREMENTS .

4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determmed in conformance with the criteria specined in Appendix J of10 CFR 50mi ;;&c re$-d nnd ;;;cici::: f ANSIN4541972:

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a. -Theee Type A tests (OverallIntegrated Contamment Leakage Rate) shallbe conducted t 10 10 : d L-t: :&* 9W 9"*d^m at either Pa (53.5 psig) or at Pt (26.8 psig) during each 10. year i service period / _ di-d tc t of;;; m chel. b; ;;;d;;^^t js " c"-2: ite rnutde--- f:- $ 10 - c . pl^-t irrerice ;"7"+4^" ,

tocM 50, App % n -

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. , e vAccusivu va idic Lcsw AAAwt i ai as abvn ava ka [ . 7.

within the nrst lu.veu m. . Me aarind. nrnvid ed a shuMas ib4A $

eurs no later th J pcHormance et the T., g A +== occurs prior to SUMMER - UNIT 1 146-2 Amencment No.%119 I

9506280257 950619 PDR ADOCK 05000395 P PDR

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i CONTAINMENT SYSTEMS l CONTAINMENT LEAKAGE Ll}11 TING CONDI.TI.ON FOR OPE.RATI_ON_ __________ __

3.6.1.2. Containment leakage rates shall be limited to:

a. An overallintegrated leakage rate of:
1. Less than or equal to La,0.20 percent by weight of the containment j air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at Pa,53.5 psig, or  ;
2. Less than or equal to Lt ,0.10 percent by weight of the containment i air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a reduced pressure of Pt ,26.8 psig. j
b. A combined leakage rate ofless than 0.60 La for all penetrations and valves subject to Type B and C tests, when pressurized to Pa.

APPLICABILITY: MODES 1,2,3 and 4. I ACTION: j With either (a) the measured overall integrated containment leakage rate exceeding 0.75 La or 0.75 Lt, as applicable, or (b) with the measured combined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 La, restore the overallintegrated leakage rate to less than or equal to 0.75 La or less than or equal to 0.75 Lt , as applicable, and the combined leakage rate for all penetrations subject to Type B and C tests to less than 0.60 La prior to increasing the Reactor Coolant System temperature above 200*F.

SURVEILLANCE REQUIREMENTS 4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determined in conformance with the criteria specified in Appendix J of10 CFR 50: l

a. Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at either Pa (53.5 psig) or at Pt (26.8 psig) during each 10-year service period in accordance with 10 CFR 50, Append ix J.

I SUMMER - UNIT 1 3/4 6-2 Amendment No. 97,119,

CONTAINMENT SYSTEMS SURVEILLANCE REQL'IREMENTS (continued)

b. L ymJA T q,e A test faih to m;;; cith:r 0.75 L, Or 0.75 L , 1 the t.es e for subsequent Type A tests.shallbe r and approved by the L '== ion. If two con e A tests failto 3' "* meet either 0.75 La or0.75 + .

est shallb'e performed at least every 18 mon wo consecu . A tests meet either 0.75 L t atwhich time the above test sc be

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c. The accuracy of each Type A test nhall be verified by a supplemental test."+h- en accocc%c , s,& Appe cliv J.

! e m n- ao o,,,,,..m, ~

s +k . ha A tout hv verifvimr th n+ +ha Nerence between supplemenfdl and Type A tesi da"ta is 0.2 3, 0.25 Lt.

ThErO 2. Has a duration su to establi urately the changein leakage rate between the and the supplementaltest.

3. Requires the ty oigas injected into ontainment or bled f e containment dunng the suppleme st to be ivalent to at least 25 percent of the total measured e
P2 53.5 pci;;;;r P 426.Speig!
d. Type B and C tests shall be conducted with gas at Pa (53.5psig)4 m aecA
m.m ..,ie ., m.oe.. .w, n --h s,g hp.a.w3 except for tests involving
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1. Air locks.

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2. Purge supply and exhaust isolation valves with resilient material seals.

t  ? urge suopiy and exnaust isolation valves with resilient material seats snall be testea ana demonstrated OPERABLE per Surveillance Requirement 4.6.1.7.3.

f. Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.
g. The provisions of Specification 4.0.2 are not applicable. ,

4 KMMER 1? NIT 1 .46-3 Amenament No.119

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

b. Deleted. l
c. The accuracy of each Type A test shall be verified by a supplemental test in accordance with Appendix J. l
d. Type B and C tests shallbe conducted with gas at Pa (53.5psig) in accordance with Appendix J except for tests involving:
1. Air locks.
2. Purge supply and exhaust isolation valves with resilient material seals.
e. Purge supply and exhaust isolation valves with resilient material seals shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.7.3.
f. Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.
g. The provisions of Specification 4.0.2 are not applicable.

SUMMER - UNIT 1 3/4 6-3 Amendment No.119,

3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1 DRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY 7-imary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from sne containment atmospnere will be restricted to those leakage oaths and associateo leak rates assumeo in the accident analyses. This restric-

  • ion, in conjunction with tne leakage rate limitation, will limit the site bouncary raciation cosas to within the limits of 10 CFR 100 during accidset conditions.

3/4.6.1.2 CONTAINMEKT LEAKAGE The If mitations on containment leakage rates (including those used in cemonstrating a 30 cay water seal) ensure that the total containment leakage volume will not exceea the value assumed in the accident analyses at the peak accicent oressure, P . As an aedeo conservatism, the measured overall inte-gratec :eakage rate is further limited to less than or ecual to 0.75 L or 0.75 L. , as acclicaole, curing performance of the ceriodic test to acc8unt for poss1cte cegracation of tne containment leakage carriers cetween leakage tests.

The surveillance testing for neasuring leaKa the recuirements of Accencix "J" Of 10 CFR 50.%ge rates are consistent with 3/a.6.1.2 REACTOR BUILDING AIR LOCKS The limitations on closure and leak rate for the reactor building air locks are recuireo to meet the restrictions on CCNTAINMENT INTEGRITY and containment leak rate. Surveillance testing of the air lock seals provide assurance that *he overall air leck leakage will not become excessive due to seal camage caring tne intervals between air lock leanage tests.

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.T e e m n .wn ' 'Le test ',t: n :1i :N:5 ' 0 * + ' * * *d M"^

tes*. wit-in :ne . '" e oeticc. as e m HPne-ey-!Cl*Ve111ance Recu1rement 4.6.1.2.a anc by ser ,

a -< Appencix J. of 10 CFR 50,

rov 1cee cai* :nsw*n occurs no later d+

than June ., ., . :n? " arf,ormance of

--e-se*

<-17 ~4r7 or' N SUMMER - LNIT 1 5 3/4 6-1 Amencment No. ff, 37

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3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restnc-tion, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of10 CFR 100 during accident conditions.

3/4.6.1.2 CONTAINMENT LE AK AGE The limitations on containment leakage rates (including those used in demonstrating a 30 day water seal) ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure, Pa. As an added conservatism, the measured overallinte-grated leakage rate is further limited to less than or equal to 0.75 La or 0.75 Li , as applicable, during performance of the periodic test to account for possible degradation of the containment leakage barriers between leakage tests.

The surveillance testing for measuring leakage rates are consistent with the requirements of Appendix "J" of 10 CFR 50. li 3/4.6.1.3 RE ACTOR BUILDING AIR LOCKS The limitations on closure and leak rate for the reactor building air locks are required to meet the restrictions on CONTAINMENT INTEGRITY and containment leak rate. Surveillance testing of the air lock seals provide assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between air lock leakage tests.

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i SUMMER - UNIT 1 B 3/4 6-1 Amendment No. 44,97,

. .. Docum:nt Control D:sk Attachm:ntII TSP 950004 RC-05-0145 Page 1 of 2 SAFETY EVALUATION FOR REVISING THE ILRT SPECIFICATION IN THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS Description of Amendment Request South Carolina Electric & Gas Company (SCE&G) proposes to modify the Virgil C.

Summer Nuclear Station (VCSNS) Technical Specifications (TS) to delete the scheduler requirement in TS 3/4.6.1.2 (Containment Leakage) for Type A Integrated Leak Rate Testing (ILRT) of containment and to delete the scheduler requirements for Type B and C testing. Additionally, the test failure and accuracy surveillance requirements as well as a footnote that is no longer applicable will be deleted. The Bases for the specification is also affected.

SCE&G requests the removal of the TS scheduler requirements and replacement with a reference to the requirements of Appendix J to 10 CFR 50. The test failure and accuracy requirements are bein : deleted as an editorial change, because they are detailed in Appendix J to 10 CF3 50. The footnote specifically refers to the :)revious Inservice Inspection (ISI) interval and does not apply; this is also considerec an ,

editorial change. l The requirements of Appendix J state that a Type A test of the containment be performed periodically, at approximately ec;ual intervals during each 10-year service

)eriod, with the third test to coincide with the shutdown for the plant 10-year l Jnservice Ins 3ection. Typically this would result in testing every other refueling outage, basec on an 18 month schedule, with the third test not necessarily coinciding with the 10-year ISI. Per the current TS, our schedule for Type A testing is every 40110 months throughout the interval.

During the first 10 year ISI, SCE&G requested and was granted a TS change (reference SER dated April 10,1991) to allow a one-time deviation from the TS l required test frequency. Since an exemption was required for the previous interval, and one will be required for the current 10 year ISI interval in order to comply with our TS requirement, SCE&G feels that this specification is unnecessarily restrictive.

SCE&G proposes to reference and comply with the requirements of Appendix J, but divide the inteivalinto periods of 4 years,3 years, and 3 years. The first ILRT of the I second ISI interval wou: d occur 4t years into this interval (Refueling Outage 10).

This schedule would coincide with our scheduled Refueling Outages and would enable VCSNS to complete the second ISI interval without having to ask for another one-time extension to allow deviation from the TS mandated test frequency. This 1 would also provide for flexibility in scheduling this test which will provide a financial l benefit to SCE&G.

Type B and C scheduler requirements are also directly addressed by Appendix J and the surveillance requirement is revised to be consistent with the direction provided throughout SR 4.6.1.2.

.. Docum:nt Control D:sk

, Attachm:nt II TSP 950004 RC-95-0145 Page 2 of 2 Safety Evaluation This proposed change will remove the TS scheduler requirement for the performance of the periodic testing of containment. Since the requirements of Appendix J to 10 CFR 50 will continue to apply the type of testing and acceptance criteria will not change. Only the detailed sch,edule for completion of this test will be deleted to provide more flexibility in scheduling of these tests. SCE&G contends that the 40i10 month period for completion of the Type A test, while meeting the requirement that the third test in the ISIinterval coincide with the 10 year ISI testing, is unnecessarily restrictive and does not provide any measurable increase in nuclear safety over that which is proposed by this change. Type B and C testing will also be governed by Appendix J with no impact to safety created by this change.

The other changes to Specification 3/4.6.1.2 are primarily editorialin nature and delete a footnote and several surveillance requirements. The footnote was included as a condition for the third test for the first ISI Interval, while the Surveillance Requirements are not required to be in TS as they are identical to requirements located in 10 CFR 50 Appendix J.

I The changes proposed, both scheduler and editorial, do not involve any significant  ;

safety risk for the following reasons: '

e The requirements of Appendix J will continue to govern the type test, I testing methodology, and acceptance criteria of Type A, B, and C testing.  !

e The test frequency is established in 10 CFR Appendix J and a specific schedule is neither included or required. l e The last three ILRTs have shown low overall containment leakage. The October 1984 test showed an overallleakage of 0.094 percent per day; the December 1988 test showed an overallleakage of 0.1057 percent per day; the March 1994 test showed an overallleakage of 0.1376 percent per day.

e NUREG 1431, the new Westinghouse Standardized Technical Specifications is consistent with this request.

The combination oflow overall leakage, the small increase in leakage between tests, the requirements in Appendix J, and the wording of NUREG 1431, shows that the pro posed change to the VCSNS TS has insignificant impact on the health and safety of the public.

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< .. Document Contrcl D:sk'

. Attachm:nt III TSP 950004 RC-95-0145

~ Page 1 of 3 NO SIGNIFICANT HAZARDS DETERMINATION FOR REVISING THE ILRT SPECIFICATION IN THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS Description of A.mendment Request South Carolina Electric & Gas Company (SCE&G) proposes to modify the Virgil C.

Summer Nuclear Station (VCSNS) Technical Specifications (TS) to delete the scheduler requirement in TS 3/4.6.1.2 (Containment Leakage) for Type A Integrated Leak Rate Testin and C testing. Ac. ;ditionally, the test failure and accuracy surveillance requireme as well as a footnote that is no longer applicable will be deleted. The Bases for the specification is also affected.

SCE&G requests the removal of the TS scheduler requirements and replacement with a reference to the requirements of Appendix J to 10 CFR 50. The test failure and accuracy requirements are being deleted as an editorial change, because they are detailed in Appendix J to 10 CFR 50. The footnote specifically refers to the ?revious Inservice Inspection (ISD interval and does not apply; this is also considerec an editorial change.

The requirements of Appendix J state that a Type A test of the containment be performed periodically, at approximately ec;ual intervals during each 10-year service period, with the third test to coincide with the shutdown for the plant 10-year Jnservice Insaection. Typically this would result in testing every other refueling outage, basec on an 18 month schedule, with the third test not necessarily coinciding with the 10-year ISI. Per the current TS, our schedule for Type A testing is every 40 10 months throughout the interval.

During the first 10 year ISI, SCE&G requested and was granted a TS change (reference SER dated April 10,1991) to allow a one-time deviation from the TS required test frequency. Since an exemption was required for the previous interval, and one will be required for the current 10 year ISIinterval in order to comply with our TS requirement, SCE&G feels that this specification is unnecessarily restrictive.

SCE&G proposes to reference and comply with the requirements of Appendix J, but divide the interval into periode of 4t years,3 years, and 3 years. The first ILRT of the second ISI interval wou: d occur 4t years into this interval (Refueling Outage 10).

This schedule would coincide with our scheduled Refueling Outages and would enable VCSNS to complete the second ISI interval without having to ask for another one-time extension to allow deviation from the TS mandated test frequency. This  ;

would also provide for flexibility in scheduling this test which will provide a financial '

benefit to SCE&G.

Type B and C scheduler requirements are also directly addressed by Appendix J and the surveillance requirement is revised to be consistent with the direction provided throughout SR 4.6.1.2.

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.. Document Control Desk

. Attachm:ntIII TSP 950004 RC-95-0145

' Page 2 of 3 Basis for No Sienificant Hazards Consideration Determination SCE&G has evaluated the proposed changes to the VCSNS TS described above against the Significant Hazards Criteria of10 CFR 50.92 and determined that the changes do not involve any significant hazard for the following reasons:

1. The probability or consequences of an accident previously evaluated is not significantly increased.

There is no increase in the probability of an accident since there is no work planned that would affect containment integrity. The testing of containment isolation valves and other containment penetration sealing devices is not postulated as an accident precursor or initiating event.

Type A testing is capable of determining the total leakage from both local leak paths as well as gross containment leakage paths. Our Type B and C testing has consistently provided accurate leakage rates for valves and penetrations.

Administrative controls govern maintenance and testing such that there is very low probability that unacceptable maintenance or alignments can occur. After maintenance on containment isolation valves (CIVs) and penetrations, a local leak rate test (LLRT) is required to be performed. All work on valves also requires that an independent valve lineup be performed. As a result, Type A testing is not required to accurately quantify the leakage through containment penetrations.

Any specific exemptions to the requirements of Appendix J will require approval by the NRC before implementation. The proposed cl.ange in itself does not affect reactor operations and does not change radiological consequences.

Therefore, this proposed change does not involve a significant increase in the possibility or consequences of an accident previously evaluated.

2. The possibility of an accident or a malfunction of a different type than any previously evaluated is not created.

The proposed TS change request (TSCR) does not involve any physical changes to the plant, affect the operation of the plant, or change testing methods or acceptance criteria. The history of containment testing verifies that containment integrity has been maintained.

The scheduler change that is proposed should not significantly decrease the level '

of confidence in the ability of the reactor building to limit offsite doses to allowable values. No accident or malfunction can be the result of the change in test schedule or frequency.

Since the proposed TSCR will not directly impact equipment, procedures or operations, the changes will not create the possibility of any new or different kind of accident from any previously evaluated.

. Document Control Desk

, Attachm:ntIII TSP 950004 RC-95-0145 Page 3 of 3

3. The margin of safety has not been significantly reduced.

The reason for performing ILRTs is to assure that the leakage paths are identified, and any accident release will be restricted to those paths assumed in the safety analysis. The purpose for the schedule is to assure that containment integrity is verified on a periodic basis.

Revising the schedule does not mean that containment integrity will be compromised. Type B and C testing will still be performed. The requirements in 10 CFR 50 Appendix J still require the testing to be performed periodically.

The testing previously performed has shown that acceptable results were obtained. The ILRT results minus the LLRT results demonstrate that most of the increases in leakage are the result of LLRT increases. These changes in Type B and C leakage are tracked and corrective action is initiated at a specific action level.

Therefore, the margin of safety has not been significantly reduced.

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