ML20087H931

Proposed Tech Specs,Proposing Extension for One Operating Cycle of Exception to LCO 3.0.4 as Applies to TS for MSIV LCS

ML20087H931
Person / Time
Site:	Perry
Issue date:	04/28/1995
From:	CENTERIOR ENERGY
To:
Shared Package
ML20087H927	List: ML20087H931
References
NUDOCS 9505050126
Download: ML20087H931 (6)

Text

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l CONTAlffENT SYSTEMS Attcchment 2

'PY-CEI/NRR-1934L' MSIV LEAKAGE CONTROL SYSTEM Page 1 of 1 LIMITING CONDITION FOR OPERATION l l

3.6.1.4 ' Two independent MSIV leakage' control system (LCS) subsystems shall be  !

OPERABLE.

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APPLICABILITY: OPERATIONAL CONDITIONS 1*, 2*, and 3*.

l ACTION:

With one MSIV lepkage control system subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 30 days 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 SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. j SURVEILLANCE REDUIREMENTS  !

t 4.6.1.4 Each MSIV leakage control system subsystem shall be demonstrated  !

OPERABLE:  ;

a. At least once per 31 days by verifying: f

1. Blower OPERABILITY by starting the blower (s) from the control room and operating the blower (s) for at least 15 minutes. .

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2. Inboard heater OPERABILITY by demonstrating electrical  !

continuity of the heating element circuitry by. verifying  :

the inboard heater draws 8.28i 10% amperes per phase.  ;

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b. During each COLD SHUTDOWN, if not performed within the previous g2 j days, by cycling each motor operated valve, including the main  ;

steam stop valves, through at.least one complete cycle of full  !

travel. l l

c. At least once per 18 months by: i

3. Performance of a functional test which includes simulated  !

actuation of the subsystem throughout its operating sequence,  !

and verifying that each automatic valve actuates to its .

correct position, and the blower (s) start (s). '

2. Verifying that the blower (s) develop (s) at least the below .

required vacuum at the rated capacity l a) Inboard system,15" H2O at 1100 scfm. ,

b) Outboard system,15' H2 O at 1200 scfm.

$ d. By verifying the inboard flow and inboard and outboard. pressure g instrumentation to be OPERABLE by performance of a:

95/y M 1.

2.

CHANNEL FUNCTIONAL TEST at least once per 31 days, and CHANNEL CALIBRATION at least once per 18 months.

Fg W

e Ig *The provisions of Specification 3.0.4 are not applicable from ga. date of this amendment until the completion of Operating Cycl effective j

PERRY - UNIT I 3/4 6-8 nt No.63 e

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- Attcchment 3 l

• PY-CEI/NRR-1934L I Page 1 of 2  !

SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the commission's Regulations, 10 CFR 50.92, which state that the operation of the facility in accordance with the proposed amendment vould not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.

The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed change does not involve a significant  !

hazard because:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

This License Amendment application proposes an extension for one operating cycle of the exception to Limiting Condition for Operation (LCO) 3.0.4 as it applies to the Technical Specification for the MSIV Leakage Control '

System. This extension is proposed for the duration of the sixth cycle of PNPP operation, to permit completion of activities necessary to implement the most appropriate permanent resolution for the issue of secondary

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containment bypass leakage through the Main Steam Line drains. During the sixth cycle, the drains vill remain in their current configuration, which -

seals off the bypass leakage path. The sealed drain path results in a temporary inoperability of the Inboard MS1V Leakage Control System (MSIV-LCS) subsystem when the plant is operated below 50% power, due to condensate build-up in the bottom of the steam lines between the MSIVs.

The requested 3.0.4 exception is necessary to permit plant startups with this temporary inoperability, for the duration of the sixth operating cycle.

The probability of occurrence of a previously evaluated accident is not affected by the proposed extension of the LC0 3.0.4 exception since no change to the plant or to the manner in which the plant is operated is involved. The existing plant configuration vill be maintained for another operating cycle, and possible concerns resulting from that configuration have been analyzed. The extra weight of the water pooled between the MSIVs was analyzed with respect to piping supports and seismic considerations and was found to be acceptable, and any condensate that is carried past the outboard MSIVs vill be drained to the condenser by drain  ;

connections downstream of the outboard MSIVs before it can reach the turbine. The temporary inoperability of the Inboard MSIV-LCS when below 50% power has no impact on accident initiation probability, since LCS does I not serve to prevent accidents, but is only used in mitigating the consequences of Loss of Coolant Accidents that have already occurred.

The consequences of an accident are not significantly increased in that the Outboard MSIV-LCS will be available to perform the MSIV-LCS function by mitigating the consequences of a Loss of Coolant Accident during the temporary period in which the Inboard MSIV-LCS is unavailable. Any condensate that is carried past the outboard MSIVs vill be drained to the condenser by drain connections downstream of the outboard MSIVs; therefore no impairment of the Outboard MSIV-LCS will result from condensed water.

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- Attechment 3 '

• PY-CEI/NRR-1934L Page 2 of 2 l The Action statement for one inoperable LCS subsystem remains the same, and limits plant operation to the previously established 30-day Allovable Outage Time. The Action required if both subsystems of MSIV-LCS vere to become inoperable also remains the same. The MSIV function of isolating the Main Steam Lines is also unaffected by the existing plant configuration, since MSIV performance vill not be affected by the existence of accumulated water in the bottom of the steam lines between the MSIVs during plant operation belov 50% power. Therefore, if necessary, the Main Steam Lines vill be isolated, and leakage past the ,

MSIVs will be routed for filtration as in the design-basis radiological t analyses, and the consequences of previously evaluated accidents vill remain unaffected.

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

The proposed change to permit inoperability of the Inboard MSIV-LCS during periods of startup and power ascension to 50% RTP and during shutdown belov 50% RTP does not create the possibility of a new or different kind of accident from any previously evaluated. The Inboard MSIV-LCS is only credited during a Recirculation Line Break LOCA wherein Reactor Coolant System depressurization occurs. The temporary unavailability of the Inboard MSIV-LCS can be mitigated by operation of the Outboard MSIV-LCS.

The amendment to the Technical Specifications is an administrative change that does not involve any change to the current plant design or methods of operation. No new plant equipment failure modes or accident initiators are introduced by the extension of the LCO 3.0.4 exception. ,

3. The proposed change does not involve a significant reduction in a margin of safety.

The response to the Recirculation Line Break LOCA vill not be significantly affected since the Outboard MSIV-LCS can be assumed to be available. Allowing entry into Operational Conditions 1, 2 and 3 while utilizing the existing Action statement does not significantly reduce the margin of safety since the duration of time allowed for remaining in that Action statement is not increased. The proposed change vill have no adverse impact on the reactor coolant system pressure boundary nor vill any other system protective boundary or safety limit be affected.

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Attachment 4 PY-CEI/NRR-1934L Page 1 of 1 CONTAINMENT SYSTEMS i

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BASES l

l 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued)

The administrative controls for both sentences of footnote ** include -

provisions that after each entry and,, exit, the OPERABLE door must be promptly closed. The allowances of footnote are acceptable because of the low probability of.an event that could pressurize the containment during the short time that the OPERABLE door will be open for entry into and exit from the containment.

The air supply to the containment air lock and seal system is the service and instrument air system. The system consists of two 100% capacity air compressors per unit and can be cross-connected. This system is redundant and extremely reliable and provides system pressure indication in the control room.

3/4.6.1.4 MSIV LEAKAGE CONTROL SYSTEM Calculated doses resulting from the maximum leakage allowance for the main steam line isolation valves in the postulated LOCA situations would be a small fraction of the 10 CFR 100 guidelines, provided the main steam line system from the isolation valves'up to and including the turbine condenser remains intact. Operating experience has indicated that degradation has occasionally occurred in the leak tightness of the MSIV's such that the specified leakage requirements have not always been maintained continuously.

The requirement for the leakage cont.rol system will reduce the untreated leakage is re from the 'C MSIV's when*Wh 5 CW isolation 15 Pr"of t{e d primary system and containmentOF8 Sad conA; quired. Aaam h Inb=A msw-L c s 9asys%

u ca3 Fd tac-s

% 8inopen in w aa 6 3/4.6.1.5 CONTAINMENT STRUCTURAL INTEGRITY d^5*4861Av a-

• ^ h'WS yue This limitation ensures that the structura7intYgYlTy ofth[carrveA %

containment will be maintained comparable to the original design standards for the life of

, the unit. Structural integrity is required to ensure that the containment will withstand the maximum pressure of 15 psig in the event of a LOCA. A visual inspection in conjunction with Type A leakage tests is sufficient to demonstrate this capability.

3/4.6.1.5 CONTAINMENT INTERNAL PRESSURE

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The limitations on primary containment to secondary containment '

differential pressure ensure that the primary containment peak pressure of l 7.80 psig does not exceed the design pressure of 15.0 psig during LOCA l  !

conditions or that the external pressure differential does not exceed the l design maximum external pressure differential of +0.8 psid. The limit of -0.1 to +1.0 psid for initial positive primary containment to secondary containment pressure will limit the primary containment pressure to 7.80 psig which is l less than the design pressure and is consistent with the safety analysis.

W W PERRY - UNIT 1 B 3/4 6-2a Amendment No.Ef,57 l

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, Attach =nt 5  :

PY-CEI/NRR-1934L MSIV LCS Paga 1 of 2 .3.6.1.9 l 3.6 CONTAINMENT SYSTEMS 1 3.6.1.9 Main Steam Isolation Valve (MSIV) Leakage Control System (LCS)  ;

LC0 3.6.1.9- Two MSIV LCS subsystems shall be OPERABLE.

5 APPLICABILITY: MODES 1. 2. and 3.

kam hcon eMen t p ;

ACTIONS Mqtopusk)C)do6. .

CONDITION COMPLETION TIME p

Ill35.Es5I+~-

A. One MSIV LCS subsyst inoperable.

M_a5LMC-subsystem to OPERABLE

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'30 days status.

B. Two MSIV LCS B.1 Restore one MSIV LCS 7 days i subsystems inoperable. subsystem to OPERABLE  ;

status. ,

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> i associated Completion Time not met. AND l C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />  !

i SURVEILLANCE REQUIREMENTS ,

SURVEILLANCE' FREQUENCY SR 3.6.1.9.1 Operate each MSIV LCS blower 31 days  !

= 15 minutes. .

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(continued)  ;

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PERRY - UNIT 1 3.6-27 Amendment No. C 1

Attachment 5

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PY-CEI/NRR-1934L MSIV LCS

• Paga 1 of 2 8 3.6.1.9 ,

BASES APPLICABLE The MSIV LCS satisfies Criterion 3 of the NRC Policy SACETY NJALYSES Statement.  !

(continued)

. LCO One MSIV LCS subsystem can provide the required processing  !

'-of the MSIV leakage. To ensure that this capability is  :

available, assuming worst case single failure two MSIV LCS  :

subsystems must be OPERABLE.  !

APPLICABILITY In MODES 1. 2 and 3. 6 DBA could lead to a fission product l release to primary containment. Therefore. MSIV LCS OPERABILITY is required during these MODES. In MODES 4 and 5. the probability and consequences of these events are .

reduced due to the pressure and temperature limitations in .

these MODES. Therefore, maintaining the MSIV LCS OPERABLE is not requircd in MODE 4 or 5 to ensure MSIV leakage is  !

processed.

ACTIONS A.1 i

With one MSIV LCS subsystem inoperable. the inoperable MSIV  :

LCS subsystem must be restored to OPERABLE status within  :

30 days. In this Condition. the remaining OPERABLE MSIV LCS ,

subsystem is adequate to perform the required leakage  :

control function. However, the overall reliability is reduced because a single failure in the remaining subsystem  !

could result in a total loss of MSIV leakage control '

function. The 30 day Completion Time is based on the i redundant capabili afforded by the remaining OPERABLE MSIV '

LCS subsystem and e low probability of a DBA LOCA occurring during this period. An L C.D L M u p c6 is PN M

+o erre ;+ u.y .% opwat cmA;mrs wkar n muk {

("S l V - L c.5- sw6 s35h 6.c. 4 5 i n o per a Ma, Am 4. mAush l B.1 witA., % 4 w msiv, %  %,,,. p w t ;, , g +,A >

b el .w sc'3, m M W A pwer.

With two MSIV LCS subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 7 days.

The 7 day Completion Time is based on the low probability of the occurrence of a DBA LOCA. j (continued) -

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PERRY - UNIT 1 B 3.6-50 Revision No. C l

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