Text

Proposed TS Bases Section 3/4.6.6,clarifying Why No Max Flow Rate Necessary in Secondary Containment Drawdown SR & Removing Action Statements of Specs 3.6.6.1 & 3.6.6.2
	ML20094L241
Person / Time
Site:	Millstone
Issue date:	11/09/1995
From:	; NORTHEAST NUCLEAR ENERGY CO.
To:	;
Shared Package
ML20094L235	List: B15424, Clarifies 950609 Proposed Rev to TS Re Secondary Containment Per 951004 Telcon W/Nrc.Revised TS Pages Encl; ML20094L241;
References
	NUDOCS 9511200122
	Download: ML20094L241 (33)
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( DEFIN!TIONS

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BECI1ON M 2.0 BEFINITIONS 3.1 ACTION .............................

1-1 3.2 ACTUATION LOGIC TEST . . . . . . . . . . . . . . . . . . . . . 11 1.3 ANALOG CENNEL OPERATIONAL TEST . . . . . . . . . . . . . . . . . 1-1 1.4 ARIAL FLUX DIFFERENCE . . . . . . . . . . . . . . . . . . . . . . 1-1 1.5 CENNEL CALIBRATION ...................... 1-1 1.8 C ENNEL CHECK . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.7 CONTA! W ENT INTEGRITY . . . . . . . . . . . . . . . . . . . . . . 1-2 1.8 CONTROLLED LEAKAGE ....................... 1-2 1.9 CORE ALTERATIONS ........................ 12 1.10 005E EQUIVALENT 1-131 . . . . . . . . . . . . . . . . . . . . . . 12 1.11 T. AVE M GE D151NTEG MT10N ENERGY . . . . . . . . . . . . . . . . . 1-2 1.121EC6R6ARY CONTAINNENT B0UNDARY).d.el*h.:J............. %

1.13 ENGINEEED SAFETY FEATURES RESPONSE TIME . . . . . . . . . . . 1-3 1.14 DELETED 1.15 FREQUENCY NOTATION ....................... 1-3 l

l 1.16 10ENTIFIED LEAKAGE ....................... 13 1.17 M STER RELAY TEST . . . . . . . . . . . . . . . . . . . . . . . . 1-3

, 2.18 NEMBER(5) 0F THE PUBLIC . . . . . . . . . . . . . . . . . . . . . 1-4

! 1.19 OPERABLE - OPERABILITY . . . . . . . . . . . . . . . . . . . . . 1-4 1.20 OPERATICML ICDI . MODE . . . . . . . . . . . . . . . . . . . . . 1-4 1.21 PHYS!C5 TESTS . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.12 PRESSURE BOUNDARY LEAKAGE . . . . . . . . . . . . . . . . . . . . 14 l 1.23 PURG E - PURG I NG . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 i 1.t4 QUADRANT POWER TILT RATIO . . . . . . . . . . . . . . . . . . . . 1-5 i 1.25 RAD 10 ACTIVE WASTE TEATENT SYSTEMS . . . . . . . . . . . . . . . 1-5 l 1.28 RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE j CALCULATIONAL E NUAL (REM 0DCM) ................. 1-5

! 1.27 RATED THERMAL POWER . . . . . . . . . . . . . . . . . . . . . . . 1-5 l 3.28 REACTOR TRIP SYSTEM ESPONSE TIME . . . . . . . . . . . . . . . . 15 1.29 E PORTABLE EVENT . . . . . . . . . . . . . . . . . . . . . . . . 1-5

1.30 SHUTDOWN E RGIN . . . . . . . . . . . . . . . . . . . . .*. . . . 1-5 l, 1.31 SITE 80UNDARY . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 j

i 9511200122 951109 i

PDR ADOCK 05000423 P PDR EIN MIT 2 4 a---*---*"- **

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LIMITING CO MITIONS FOR OPERATION AE SURVEILLANCE REQUIRENENTS i

3EI1011 f.AE l 3/4 6-9 Air Temperature . . . . . . . . . . . . . . . . . . .

j' Containment Structural Int'ogrity . . . . . . . . . . . 3/4 6-10 1 Containment Ventilation System . . . . . . . . . . . . 3/4 6-11 f 3/4.5.2 DEPRES$URIZATION AND C0OLING SYSTEMS j ' Containment Quench Spray System . . . . . . . . . . . 3/4 6-12 ffI Recirculation Spray System . . . . . . . . . . . . . . 3/4 6-13 V

j 3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . . . . . . . . 3/4 6-15

] 3/4.6.4 COMBUSTIBLE GAS CONTROL Hydrogen Monitors . . . . . . . . . . . . . . . . . . 3/4 6-16 l Electric Hydrogen Recombiners . . . . . . . . . . . . 3/4 6-17 i

l 3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM Steam Jet Air Ejector . . . . . . . . . . . . . . . . 3/4 6-18 l

l 3/4.6.6 SECONDARY CONTAINMENT j Supplementary Leak Collection and Release System . . . 3/4 6-19 l Secondary Containment @ . . . . . . . . . . . . 3/4 6 22 i

Secondary Containment Boundary f * .-

Structural Integrity . . . .=. . . . . . . . . . . . . 3/4 6-23 l

3/4.7 PLANT SYSTEMS i

j 3/4.7.1 TURBINE CYCLE

! Safety Valves ..................... 3/47-1

) TABLE 3.7-1 MAXIMUM ALLGWABLE POWER RANGE NEUTRON FLUX HIGH i SETPOINT WITH INOPERABLE STEAM LINE SAFETY VALVES DURING FOUR LOOP OPERATION ............... 3/4 7-2

TABLE 3.7-2 MAXIMUM ALLOWABLE POWER RANGE NEUTRON FLUX HIGH

SETPOINT WITH INOPERABLE STEAM LINE SAFETY VALVES l DURING THREE LOOP OPERATION .............. 3/47-2 l

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MILLSTONE - LBt!T 3 ix Amendment No. 77 77 57 77. 177 115 m

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" P 12/03/;3-e i arrrNITIoNs i

o i( (src8NDRITMNTAD64ENT arummny > g,j ,pe.4 , ,

i 1.12 SThe SECONDARY CONTAINMENT SOUNDARY is comprised of the containment j

Wesure buildini and all contiguous buildings [ main steam valve bui

! [ partially), ontneering safety features build'ng jpartially), hydrogen !

i recombiner builting [ partially), and auxiliary bulld ng). The SECONDARY l l t0NTAINNENT B0UNDARY shall exist when: '

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i a. Each door in each access opening is closed except when the access

! spaning is being used for normal transit entry and exit.

l The sealing mechanism associated with each penetration (e.g.,

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welds, bellows. or 0-rings) is OPERABLE. -

i ENGINEERED SAFETY FEATURES RESPONSE TIME 1.13 The ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF Actuation Setpoint i at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their utred positions, pump discharge pressures reach their required values, etc. . Times shall include

. diesel generator starting and sequence loading delays are applicable.

1.14 Deleted .

( FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

IDENTIFIED LEAKAGE 1.1 IDENTIFIED LEAKAGE shall be:

a. Leakage Coxcept CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located ared known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE '

BOUNDARY LEAKAGE, or

c. Reactor Coolant Systen leakage through a steam generator to the Secondary Coolant Systeis.

MASTERRELAY_ TEST 1.17 A MASTER RELAY TEST shall be the energization of each master relay and verification of CPERABILITY of each relay. The MASTER RELAY TEST shall include a continuity check of each associated slave relay.

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WILL5T0hE - 4381T 3 1-3 Amendment No. M.87 eies

CONTAfNMENT SYSTEMS om

- . . . , e, _ _,m CONTAIMMENT LEAKAGE LIMITING CONDITION FOR OPERATION q

3.6.1.2 Containment leakage rates shall be limited to:

a. An overall integrated leakage rate of less than or equal to L.,

0.31r, by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at P.,

53.27 psia (38.57 psig);

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b. A combined leakage rate of less than 0.60 L, for all penetrations ;

and valves subject to Type 8 and C tests, when pressurized to P ; l and

c. A combined leakage rat _e of less than or equal to 0.042 L, for all i penetrations that are L5LCONa7AKT bunlNnntna DUUNMinM bypass leakage l

, paths when pressurizac w r..

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PptfCABILITY: MODES 1, 2, 3, and 4. 9 l ACTION:

With the measured overall integrated containment leakage rate exceeding 0.75 L., or the measured combined leakage rate for all penetrations and valves subject to Type B and C tests exceeding 0.60 L., or the combined bypass leakage rate exceeding 0.042 L., restore the overall integrated leakage rate to less than 0.75 L., the combined leakage rate for all penetrations subject 7 to Type B and C tests to less than 0.60 L., and the combined bypass leakage >

rate to less than 0.042 L 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 4

test schedule and shall be determined in conformance with the criteria

! specified in Appendix J of 30 CFR Part 50 using methods and provisions of ANSI l N45.4-Ig72 (Total Time Method) and/or ANSI /ANS 56.8-1g83 (Mass Point Method):

, s. Three Type A tests (0verall Integrated Containment Leakage Rate)

)J i shall be conducted at approximately equal intervals during shutdown [

i at a pressure not less tian P., 53.27 psia (38.57 psig), during each 10-year service period.*

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If any periodic Type A test fails to meet 0.75 L b.

for subsequent Type A tests shall be reviewed an., the test schedule d approved by the commission. If two consecutive Type .A tests fail to meet 0.75 L., a i

Type A test shall be performed at least every 18 months until two

, consecutive Type A tests meet 0.75 L at which time the above test j schedule may be resumed; i

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The third Type A test will be conducted during the sixth refueling outage. As a result, the duration of the first 10-year service period will be extended to the end of the sixth refueling outage.

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MILLSTONE - UNIT 3 3/4 6-2 Amendment No. Jf, J7, Jf,111

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NO C h cr ny RR /NSO ONL Y January 3,1995 CONTAllOIENT SYSTEMS 3/4.6.6 SEcolSARY CONTAlpflENT SUPPLEMENTARY LEAK COLLECTION AND RELEASE SYSTEN -

LINITIIIS C0fBITION FOR OPERATION l 3.6.6.1 Two independent Supplementary Leak Collection and Release Systems shall be OPERABLE with each system comprised of:

a. one OPERABLE filter and fan, and ;

b. one OPERABLE Auxiliary Building Filter System as defined in Specification 3.7.9.

APPLICABILITY: MODES 1, 2, 3, and 4. !

EllGH:

With one Supplementary Leak Collection and Release System inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT !

STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following I 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . l SURVEILLANCE REQUIRENENTS

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4.6.6.1 Each Supplementary Leak Collection and Release System shall be demon-q strated OPERABLE:

! a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, 1

from the control room, flow through the HEPA filters and charcoal adsorbers and verifying a system flow rate of 7600 cfm to 9800 cfm l and that the system operates for at least 10 continuous hours with the heaters operating.

! b. At least once per IB months or (1) after any structural raintenance on the HEPA filter or charcoal adsorber housings, or (2) following

! painting, fire, or chemical release in any ventilation zone communi-cating with the system by:

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3 1) Verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than

, 0.05% and uses the test procedure guidance in Regulatory Posi- -

i tions C.5.a. C.5.c, and C.5.d of Regulatory Guide 1.52, Revi-sion 2, March 1978,* and the system flow rate is 7600 cfm to 9800 cfs; j

N f 0NE - ISIIT 3 3/4 6-19 Amendment No. p. pp, 57.

100

l 9 11"ne"l2,1205-i CONTAD9 TENT SYSTEMS SURVE!LLANCE REQUIREMENTS (Continued)

2) within 31 days after removal, that a laboratory Verifying,f analysis o a representative carbon sample obtained in accord-ance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,* meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978,* for a methyl lodida penetration of less than 0.1755; and

3) Verifying a system flow rate of 7600 cfm to 9800 cfm during system operation when tested in accordance with ANSI N510-1980.

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation, by verifying, within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2. March 1978,*

meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978,* for a methyl iodide penetration of less than 0.175%:

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d. At least once per 18 months by: )

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1) Verifying that the pressure drop across the combined HEPA I filters and charcoal adsorber banks is less than 6.25 inches i Water Gauge while operating the system at a flow rate of j 7600 cfm to 9800 cfa,

! 2) Verifying that the systes starts on a Safety Injection test i signal, and ,.,

[ Verifying greater thanthator equal eachtosystem 0.4 inchproduces Water ative pressure of a a 1 auge in the Auxiliary i

Buildingat24'6'elevationwithin120secondsafterastartj signalfand

' 3.Af Verifying that the heaters dissipate 5015 kW when tested in accordance with ANSI R510-1980.

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ANSI N5101980 shall be used in place of ANSI M510-1975 referenced in Regulatory Guide 1.52. Revision 2, March 1978.

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in s:o awiy January 3,1995 l t

CONTAINMDff SYSTEMS ,

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SURVEILLANCE REQUIRDIDfTS (Continued) l

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup systen satisfies the in-place penetration i and bypass leakage testing acceptance criteria of less than 0.05% in '

accordance with ANSI N510-1980 for a 00P test aerosol while operating the system at a flow rate of 7600 cfm to 9800 cfa; and i

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place ,

penetration and bypass leakage testing acceptance criteria of less '

than 0.05% in accordance with ANSI M510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 7600 cfa to 9800 cfa.

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g p - UNIT 3 s/46-21 Amenment me. g, 77, 77.

! _ . . ._. . ._. . _ _ _ _ _ _ __ 1.0 0 _ _ _-- --

(Jihuary 33A CONTAllplENT SYSTEMS -

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SEcolBARY C00frAllBlDfflBOUBBARY)

LIMITING COMITION FOR OPERATION

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3.6.6.2 (SfC0NDARY_ CONTAINNENL800NDARLsha1Lbe_ maintained: $

E.c(cear.y Coo h -~ent acal b e orec^etE !

APPLICABILITY: MODES I, 2, 3, and 4. 9 E' set endce wY Corb4M incena W S

/ uc'd"9 Os*MopstzA S&

With JJE within 24'(ONDARLCONTAIMENLBOUNDARY),

hours or be in at least HOT STANDBY withTnrestore thi nikt 6{5ECONDARV~dfNTAQh NENT~ BOUND 8RY COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIRENENT o pems.u y or .s medav mam*e 4.6.6.2.L LtECONDARY CONTAINkw+shall W be demonstrated at least once per ! l 31 days by verifying that each door in each access opening is closed except when i the access opening is being used for normal transit entry and exit.

g c; . (, 7.1. M-\eu* on<c ew \ 9, m en w s ,v e w W7 ecuh Swe\a6m Wy Lp,4 CA cthen card Ro \ cia c. N d< vw p dw u 3 auf% ve_ p u c. I m a, k Cf 'd 8Y MC4w UY R cgwd k C. At d \A) q b (jrt u g N hHt. bu v dic4]

smsug a wLc" s~caon mm (2e su as oh a sb,4 u pu.\-

1 i MILLSTONE - IBl!T 3 3/4 6-22 Amendment No. F l 100

_ .. __.~- _:_ ;_ ..

, i f A.,seri 3,1005 -

l CONTAINNDff SYSTDi$

l ggNDARY CONTAINMDfTIBOUND STRUCTURAL UffEstffY -

LIMITING CONDITI M FOR OPERATI M

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3.6.5,3 The structural integrity of the ?E000= OeiGAliinidi 5Gi OA"Y shall be maint Ained et a level consistent with the acceptance criteria in Specification 4.6.6.3.

4 f A!2LIL\llGII: MODES 1, 2, 3. and 4.

q w,, .te,7 C"M '

f EIIM: p With the structural integrity of thef5fCONDARY CONTAINMENT B0UND5RT not conforming to l' the above requirenents, restore the structural integrity to within the limits i within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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! c, cr j W gd l SURVEILLANCE REQUIRENENT / //

4.6.6.3 The structural inte rity of the 5Ewnu ONT EST shall be determined during the shutdown for each Type A containment' lea ege rate test (reference Specification 4.6.1.2) by a visual insnection of the ex>dsed ccessible interior l and exterior surfaces of the p reNDKKF CONTAINMENT BOUN)ARY nd verifying no apparent real degradation. Any changes in appearance of theof the(concrete surfaces ora t Lr abECONDAM EDNTAIN I abnormal degradation i required inspections shall be reported to the Coenission in a Special Report pursuant to Specification 6.9.2 within 15 days.

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< AmendmentNo.F7

- NILLSTONE - IBl!T 3 3/46-23

em 100 i

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12/"493 i : .

l caminnEn systEns l BASES 1

) F4.6.6 SECONDARY CONTAllelENT 2/L6.6.1 SUPPLEMENTARY LEAK GOLLECTION AND RELEASE SYSTEM Backaround 1 The OPERABILITY of the Supplementary Leak Collection and Release System 1 (SLCRS) ensures that radioactive materials that leak from the primary contain-i ment into the secondary containment following a Design Basis Accident (_DBA are filtered out and adsorbed prior to any release to the environment.1 T e

) idesign of thTSECRSTiTo achleve a negative 7ressureYithT6 the seconcary j Eontainment_boundaryarithin320_ seconds _of a 2A4

___ DeJekt '

I In order to ensure a negative pressure in all areas within the secondary l

containmentboundaryundermostmeteorologicalconditions,thenegative pressure acceptance criteria at the measured location (i.e., 24'6 elevation in the auxiliary building) is 0.4 inches water gauge.

1 The secondary containment boundary is comprised of the containment enclosure building and all contiguous buildings (main steam valve building (partially),

engineeredsafetyfeaturesbuilding(partially)lishthis,theSLCRSworksin, (partially) and auxiliary building i. To accomp hydrogen rec conjunctionwiththeAuxiliaryBu11dingFilter(ABF) system (seeSec-3 tion 3/4.7.9). The SLCRS and the ABF fans and filtration units are located in i the auxiliary building. The SLCRS is described in the Millstone Unit No. 3 m l FSAR, Section 6.2.3. I ~

b elicable safety Analyses

The SLCRS design basis is established by the consequences of the j limiting DBA, which is a LOCA. The accident analysis assumes that only one

train of the SLCRS and one train of the auxiliary building filter system is

! functional due to a' single failure that disables the other train. The i accident analysis accounts for the reduction of the airborne radioactive l material provided by the remaining one train of this flitration system. The

j. amount of fission products available for release from the containment is

determined for a LOCA.

The SLCRS is not normally in operation. The SLCRS starts on a SIS l signal. The modeled SLCRS actuation in the safety analysis (the Millstone 3 FSAR Chapter 15, Section 15.6) is based upon a worst-case response time l following an $1 initiated .it the limiting setpoint. One train of the SLCRS in conjunctnen with the ABF system is capab e of drawin9 a negative pressure

! (0.4 inches water gauge __at the auxiliary building 24 6" elevation) within

120 seconds after a LOCA. This time includes diesel generator startup and

! sequencing time, system startup time, and time for the system to attain the

required negative pressure after starting.

! NILLSTONE - IBtIT 3 3 3/4 6-4 Amendment No. 87 4

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CONTAI M SYSTDis BASES 1/4.5.6.1 SUPPLDIENTARY LEAK COLLECTION AND RELEASE SYSTEM (Continued)

ISO .

In the event of a DBA, one SLCRS is required to provide the minimum postulated iodine removal assumed in the safety analysis. Two trains of the SLCRS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single-active failure. The SLCPS works in conjunction with the ABF system. Inoperability of one train of the ABF system also results in inoperability of the corresponding train of the SLCRS. Therefore, whenever LC0 3.7.9 is entered due to the ABF train A (B) being inoperable, LC0 3.6.6.1 must be entered due to the SLCRS train A (B) being inoperable. 5 ,

b i #0SE ET-Ann 11cability In MODES I, 2,3, and 4, a DBA could lead to a f4ssion pr_oduct release to containment that leaks to the secondary containment boundar

. break LOCA, on which this system's design is based,power is a event.

fuT1y1e large Less severe LOCAs and leakage still require the system to be OPERABLE through-out these MODES. The probability and severity of a LOCA decrease as core power and reactor coolant system pressure decrease. With the reactor shut down, the probability of release of radioactivity resulting from such an accident is low.

In MODES 5 and 6, the probability and consequences of a DBA are low due l to the pressure and temperature limitations in these MODES. Under these conditions, the SLCRS is not required to be OPERABLE.

! ACTIONS -

! With one SLCRS train inoperable, the inoperable train must be restored i to OPERABLE status within 7 days. The operable train is capable of providing i 100 percent of the iodine removal needs for a DBA. The 7-day Completion Time l

1s based on consideration of such factors as the reliability of tte OPERABLE i redundant SLCRS train and the low probability of a DBA occurring during this period. The Completion Time is adequate to make most repairs. If the SLCRS cannot be restored to OPERABLE status within the required Completion Time, the

! plant must be brought to a M00E in which the LC0 does not apply. To ach'leve 1 this status, the p ant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and

! fEIDE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed Completion Times are

! reasonable, based on operating experience, to reach the required plant

conditions from full-power conditions in an orderly manner and without

challenging plant systems.

NILLSTONE - IBi1T 3 est 83/46-5 Amendment No. 87 1

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l Insert 'B' to Page B 3/4 6-5 LCQ When a Supplementary Leak Collection and Release System LCO is not met, it is not necessary to declare the secondary containment inoperable. However, in this event, it is necessary to determine that a loss of safety function does not exist. A loss of safety function exists when, assuming no concurrent single

failure, a safety function assumed in the accident analysis cannot be performed.

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too chmyn pug m po cmu y 12/08/93 i .

l CWffAIMIENT SYSTDIS RASES

. t l 3/4.6.6.1 SUPPLEMENTARYLEAKCOLLECTIONANDRELEASESYSTEM(Continued) j Barve111ance Renuirements f Cumulative operation of the SLCRS with heaters operating for at least 10 i continuous hours in a 31-day period is sufficient to reduce the butidup of

moisture on the adsorbers and HEPA filters. The 31-day frequency was

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developed in consideration of the known reliability of fan motors and con-

trols. This test is performed on a STAGGERED TEST BASIS once per 31-days.

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] b. c. e. and f i These surveillances verify that the required SLCRS filter testing is 1 performed in accordance with Regulatory Guide 1.52, Revision 2. ANSI

N510-1980 shall be used'in place of ANSI N510-Ig75 referenced in Regulatory Guide 1.52, Revision 2. The surveillances include testing HEPA filter i - performance, charcoal adsorber efficiency, system flow rate, and the physical i properties of the activated charcoal (general use and following specific j operations).

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{ The automatic startup ensures that each SLCRS train responds properly.

The 18-month frequency is based on the need to perform this surveillance under 1

the conditions that apply during a plant outage and the potential for an

unplanned transient if the surveillance was prformed with the reactor at power. The surveillance verifles that the S.CRS starts on a SIS test signal.

It also includes the automatic functions to isolate the other ventilation

, systems that are not part of the safety-related postaccident operating

configuration and to start up and to align the ventilation systems that flow l

through the secondary containment to the accident condition.

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The main steam valve building ventilation system isolates.

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Auxiliary building ventilation (normal) system isolates.

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Charging pump / reactor plant component cooling water pump area cooling j subsystem aligns and discharges to the auxiliary building filters and a i filter fan starts. -

Hydrogen recombiner ventilation system aligns to the postaccident

. configuration.

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The engineered safety features building ventilation system aligns to the postaccident configuration.

WILLSTONE - Isl!T 3 3 3/4 6-6 Amendment No. 87 i

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ColffAlletENT SYSTDiS

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3/4.6.6.1 SUPPLENENTARYLEAKCOLLECTIONANDRELEASESYSTEN(Continued),

IHth the SLCRS in postaccident configuration, the required negative pressure in the secondary containment boundary is achieved in 110 seconds from the time i of simulated emergency diesel generator. breaker closure. Time delays of l dampers and logic delays must be accounted for in this surveillance. The time 1 to achieve the required negative pressure is 120 seconds, with a loss-of-i effsite power coincident with a SIS. The surveillance verifies that one train j of SLCRS in conjunction with the ABF system will produce a negative pressure

of 0.4 inches water gauge at the auxiliary building 24'6" elevation relative i 'to the outside atmosphere in the secondary containment boundary. For the 3 purpose of this surveillance, pressure measurements will be made at the 24'6" i~ elevation in the auxiliary building. This single location is considered to be ;

l adequate and representative of the entire secondary containment due to the l 1 large cross-section of the air passages which interconnect the various i j bui dings within the boundary. In order to ensure a negative pressure in all ,

! areas inside the secondary containment boundary under most meteorological l conditions, the negative pressure acceptance criteria at the measured location is 0.4 inches water gauge. It is recognized that there will be an occasional meteorological condition under which s ightly positive pressure may exist at some loca ized portions of the boundary (e.g., the upper elevations on the down wind side of a building). For example, a very low outside temperature combined with a moderate wind speed could cause a slightly positive pressure

at the upper elevations of the containment enclosure building on the leeward face. The probability of occurrence of meteorological conditions which could result in such a positive differential pressure condition in the upper levels

of the enclosure ouilding has been estimated to be less than 2% of the time.

t l The probability of wind speed within the necessary moderate band, combined i with the probability of extreme low temperature, combined with the small

! portion of the boundary affected, combined with the low probability of l airborne radioactive material migrating to the upper levels ensure that the l

overall effect on the design basis dose calculations is insignificant.

3/4.6.6.2 SECONDARY CONTAINNENT B0UNDARY

! SECONDARY CONTAllelENT B0UNDARY ensures that the release of radioactive

! anterials from the primary containment atmosphere will be restricted to those

! leakage paths and associated leak rates assumed in the safety analyses. This j restriction, in conjunction with operation of the Supplementary Leak

Collection and Release system, and Auxiliary Building Filter System will limit

the SITE B0UNDARY radiation doses to within the dose guideline values of 10

CFR part 100 during accident conditions, f

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g p - IBl!T 3 53/46-7 Amendment No. 87 l

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i993 MNTMMEN SYMS g

2/4.s.s.3 SECONDARY CONTAlletENT BOUNDARY STRUCTURAL INTEGRITY ~]

This limitation ensures that the structural integrity of the SECONDARY j CONTAIMENT B0UNDARY will be maintained comparable to the original design 1

, standards for the life of the facility. Structural integrity is required to

] provideasecondaryboundarysurroundingtheprimarycontainmentthatcanbe[ -

! maintained at a negative pressure during accident conditions. A visual 1 inspection is sufficient to demonstrate this capability. . - - -

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4 R4LLSTME - 15 FIT 3 8 3/4 5 8 Amendment No. 87

INSERT A to Page 1 of 4 Page B 3/4 6-7 3/4.6.6.2 SECONDARY CONTAINMENT The Secondary Containment is comprised of the containment enclosure building and all contiguous buildings (main steam valve building [ partially),

engineering safety features building [ partially), hydrogen recombiner building

[2artially), and auxiliary building). The Secondary Containment shall exist wien:

a. Each door in each access opening is closed except when the access opening is being used for normal transit entry and exit,

b. The sealing mechanism associated with each penetration (e.g., welds, !

bellows, or 0-rings) is OPERABLE.

Secondary Containment ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with operation of the Supplementary Leak Collection and Release System, and Auxiliary Building Filter System will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.

The SLCRS and the ABF fans and filtration units are located in the auxiliary building. The SLCRS is described in the Millstone Unit No. 3 FSAR, Section 6.2.3.

In order to ensure a negative pressure in all areas within the Secondary Containment under most meteorological conditions, the negative pressure acceptance criterion at the measured location (i.e., 24'6" elevation in the auxiliary building) is 0.4 inches water gauge.

l LCD

, The Secondary Containment OPERABILITY must be maintained to ensure proper

operation of the SLCRS and the auxiliary building filter system and to limit

. radioactive leakage from the containment to those paths and leakage rates assumed

' in the accident analyses.

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Applicability

! Maintaining Secondary Containment OPERABILITY prevents leakage of

)- radioactive material from the Secondary Containment. Radioactive material may

, enter the Secondary Containment from the containment following a LOCA.

~ Therefore, Secondary Containment is required in MODES 1, 2, 3, and 4 when a design basis accident such as a LOCA could release radioactive material to the j containment atmosphere.

In MODES 5 and 6, the probability and consequences of a DBA are low due to

, the RCS temperature and pressure limitation in these MODES. Therefore, Secondary

Containment is not required in MODES 5 and 6.

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- . l Page 2 of 4 ACTIONS In the event Secondary Containment OPERABILITY is not maintained, Secondary l Containment OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Twenty-four hours is' :

a reasonable Completion Time considering the limited leakage design of !

containment and the low probability of a DBA occurring during this time period. i Therefore, it is considered that there exists no loss of safety function while i in the ACTION Statement.

Inoperability of the Secondary Containment does not make the SLCRS fans and i filters inoperable. Therefore, while in this Action Statement solely due to ,

inoperability of the Secondary Containment, the conditions and required actions ;

associated with Specification 3.6.6.1 (i.e., Supplementary Leak Collection and 1 Release System) are not required to be entered. If the Secondary Containment !

OPERABILITY cannot be restored to OPERABLE status within the required completion ;

time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ;

and to MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed Completion Times are ;

reasonable, based on operating experience, to reach the required plant conditions i from full-power conditions in an orderly manner and without challenging plant j systems. )

Surveillance Reauirements 4.6.G.2.1 Maintaining Secondary Containment OPERABILITY requires maintaining each door in each access opening in a closed position except when the access opening is being used for normal entry and exit. The normal time allowed for passage of equipment and personnel through each access opening at a time is defined as no more than 5 minutes. The access opening shall not be blocked open. During this time, it is not considered necessary to enter the action statement. A 5-minute time is considered acceptable since the access opening can be quickly closed without special provisions and the probability of occurrence of a DBA concurrent with equipment and/or personnel transit time of 5 minutes is low.

The 31-day frequency for this surveillance is based on engineering judgment I and is considered adequate in view of the other indications of access opening ,

status that are available to the operator. !

4.6.6.2.2 The ability of a SLCRS to produce the required negative pressure during the test operation within the required time provides assurance that the Secondary Containment is adequately sealed.

With the SLCRS in postaccident configuration, the required negative pressure in the Secondary Containment is achieved in 110 seconds from the time of- simulated emergency diesel generator breaker closure. Time delays of dampers and logic delays must be accounted for in this surveillance. The time to achieve the required negative pressure is 120 seconds, with a loss-of-offsite power coincident with a SIS. The surveillance verifies that one train of SLCRS in

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- Page 3 of 4 conjunction with the ABF system will produce a negative pressure of 0.4 inches water gauge at the auxiliary building 24'6" elevation relative to the outside atmosphere in the Secondary Containment. For the purpose of this surveillance, pressure measurements wn1 be made at the 24'6" elevation in the auxiliary building. This single locetion is considered to be adequate and representative of the entire Secondary Co1tainment due to the large cross-section of the air passages which interconnect the various buildings within the Secondary Containment. In order to ensure a negative pressure in all areas inside the Secondary Containment under most meteorological conditions, the negative pressure acceptance criterion at the measured location is 0.4 inch water gauge. It is recognized that there will be an occasional meteorological condition under which slightly positive pressure may exist at some localized portions of the boundary (e.g., the upper elevations on the down-wind side of a building). For example, a very low outside temperature combined with a moderate wind speed could cause a slightly positive pressure at the upper elevations of the containment enclosure building on the leeward face. The probability of occurrence of meteorological conditions which could result in such a positive differential pressure condition ;

in the upper levels of the enclosure building has been estimated to be less than 2% of the time. 1 The probability of wind speed within the necessary moderate band, combined with the probability of extreme low temperature, combined with the small portion of the boundary affected, combined with the low probability of airborne ,

radioactive material migrating to the upper levels ensures that the overall i effect on the design basis dose calculations is insignificant. l l

The SLCRS system and fan sizing was based on an estimated infiltration rate. The fan flow rates are verified within a minimum and maximum on a monthly basis. Initial testing verified that the drawdown criterion was met at the lowest acceptable flow rate. The new standard Technical Specification i (NVREG-1431) 3.6.6.2 surveillance requirement requires that the drawdown j criterion be met while not exceeding a maximum flow rate. It is assumed that the i purpose of this flow limit is to ensure that adequate attention is given to l maintain the SLCRS boundary integrity and not using excess system capacity to cover for boundary degradation.

The SLCRS system was designed with minimal margin and, therefore, does not !

have excess capacity that can be substituted for boundary integrity. l Additionally, since SLCRS fan flow rates are verified to be acceptable on a more I frequent basis than the drawdown test surveillance, and by means of previous i testing the minimum flow rate is acceptable, verifying a flow rate during the i drawdown test would not provide an added benefit. Historical SLCRS flow '

measurements show a lack of repeatability associated with the inaccuracies of air flow measurement. As a result, the more reliable verification of tystem performance is the actual negative pressure generated by the drawdown test and a measured flow rate would add little.

3/4.6.6.3 SECONDARY CONTAINMENT STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of the Secondary Containment will be maintaind comparable to the original design standards for the life of the facility. Structural integrity is required to provide a l

i-Page 4 of 4 secondary boundary surrounding the primary contai ment that can be maintained at a negative pressure during accident conditions. i visual inspection is suffi-cient to demonstrate this capability.

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Docket No. 50-423 B15424 Attachment 2 :

Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Secondary Containment - Additional Information Retyped Pages I

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November 1995 I

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IM2EE DEFINITIONS SECTION _

EME 1.0 DEFINITIONS 1.1 ACTION ............................. 1-1

1.2 ACTUATION LOGIC TEST ...................... 1-1

] 1.3 ANALOG CHANNEL OPERATIONAL TEST . . . . . . . . . . . . . . . . . 1-1 1.4 AXIAL FLUX DIFFERENCE . . . . . . . . . . . . . . . . . . . . . . 1-1 1.5 CHANNEL CALIBRATION ...................... 1-1 1.6 CHANNEL CHECK . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.7 CONTAINMENT INTEGRITY . . . . . . . . . . . . . . . . . . . . . . 1-2 1.8 CONTROLLED LEAKAGE ....................... 1-2 4

1.9 CORE ALTERATIONS ........................ 1-2 1.10 DOSE EQUIVALENT l-131 . . . . . . . . . . . . . . . . . . . . . . 1-2 i 1.11 E-AVERAGE DISINTEGRATION ENERGY . . . . . . . . . . . . . . . . . 1-2 1.12 DELETED l l.13 ENGINEERED SAFETY FEATURES RESPONSE TIME ............ 1-3 q 1.14 DELETED 1.15 FREQUENCY NOTATION ....................... 1-3 1.16 IDENTIFIED LEAKAGE ....................... 1-3 1.17 MASTER RELAY TEST . . . . . . . . . . . . . . . . . . . . . . . . 1-3 I 1.18 MEMBER (S) 0F THE PUBLIC . . . . . . . . . . . . . . . . . . . . . 1-4 1.19 OPERABLE - OPERABILITY ..................... 1-4 l

1.20 OPERATIONAL MODE - MODE . . . . . . . . . . . . . . . . . . . . . 1-4 1.21 PHYSICS TESTS . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 1.22 PRESSURE BOUNDARY LEAXAGE . . . . . . . . . . . . . . . . . . . . 1-4 1.23 PURGE - PURGING . . . . . . . . . . . . . . . . . . . . . . . . . 1-4 1.24 QUADRANT POWER TILT RATIO . . . . . . . . . . . . . . . . . . . . 1-5 1.25 RADIDACTIVE WASTE TREATMENT SYSTEMS . . . . . . . . . . . . . . . 1-5

1.26 RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE 1

CALCULATIONAL MANUAL (REMODCM) ................. 1-5 1.27 RATED THERMAL POWER . . . . . . . . . . . . . . . . . . . . . . . 1-5 1.28 REACTOR TRIP SYSTEM RESPONSE TIME . . . . . . . . . . . . . . . . 1-5 1.29 REPORTABLE EVENT ........................ 1-5 1.30 SHUTDOWN MARGIN . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 1.31 SITE BOUNDARY . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 4

MILLSTONE - UNIT 3 i Amendment No. pf, 77, essa

. I!Elfl LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 1

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SECTION PAGE Air Temperature . . . . . . . . . . . . . . . . . . . 3/4 6-9 i l Containment Structural Integrity . . . . . . . . . . . 3/4 6-10 Containment Ventilation System . . . . . . . . . . . . 3/4 6-11

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3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS Containment Quench Spray System . . . . . . . . . . . 3/4 6-12 Recirculation Spray System . . . . . . . . . . . . . . 3/4 6-13

3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . . . . . . . . 3/4 6-15 3/4.6.4 COMBUSTIBLE GAS CONTROL l Hydrogen Monitors . . . . . . . . . . . . . . . . . . 3/4 6-16 I Electric Hydrogen Recombiners . . . . . . . . . . . . 3/4 6-17

3/4.6.5 $UBATMOSPHERIC PRESSURE CONTROL SYSTEM Steam Jet Air Ejector . . . . . . . . . . . . . . . . 3/4 6-18 3/4.6.6 SECONDARY CONTAINMENT Supplementary Leak Collection and Release System . . . 3/4 6-19 Secondary Containment . . . . . . . . . . . . . . . . 3/4 6-22 Secondary Containment Structural Integrity . . . . . . . . . . . . . . . . . 3/4 6-23 1

3/4.7 PLANT SYSTEMS j 3/4.7.1 TURBINE CYCLE Safety Valves ..................... 3/4 7-1 i

TABLE 3.7-1 MAXIMUM ALLOWABLE POWER RANGE NEUTRON FLUX HIGH SETPOINT WITH INOPERABLE STEAM LINE SAFETY VALVES DURING FOUR LOOP OPERATION ............... 3/4 7-2 TABLE 3.7-2 MAXIMUM ALLOWABLE POWER RANGE NEUTRON FLUX HIGH SETPOINT WITH INOPERABLE STEAM LINE SAFETY VALVES DURING THREE LOOP OPERATION .............. 3/4 7-2 l

MILLSTONE - UNIT 3 1x Amendment No. 77,77,77,77,JPP,

- - 119,

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l DEFINITIONS 1.12 DELETED l ENGINEERED SAFETY FEATURES RESPONSE TIME 1.13 The ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF Actuation Setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures rauh their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable.

1.14 Deleted FREQUENCY NOTATION

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1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

IDENTIFIED LEAKAGE 1.1 IDENTIFIED LEAKAGE shall be:

a. Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE BOUNDARY LEAKAGE, or

c. Reactor Coolant System leakage through a steam generator to the Secondary Coolant System.

MASTER RELAY TEST 1.17 A MASTER RELAY TEST shall be the energization of each master relay and verification of OPERABILITY of each relay. The MASTER RELAY TEST shall include continuity check of each associated slave relay. i l

NILLSTONE - UNIT 3 1-3 Amendment No. M , 77, om

CONTA110 TENT SYSTEMS CONTAllBIENT LEAKAGE LIMITING C0fGITION FOR OPERATION 1

3.6.1.2 Containment leakage rates shall be limited to: -

i a. An overall integrated leakage rate of less than or equal to L.,

0.3f,by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at P.,

53.27 psia (38.57 psig);

j b. A combined leakage rate of less than 0.60 L, for all penetrations f 1 and valves subject to Type B and C tests, when pressurized to P,;

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! c. A combined leakage rate of less than or equal to 0.042 L, for all i j . penetrations that are Secondary Containment bypass leakage paths l I

when pressurized to P,. l APPLICABILITY: N0 DES 1, 2, 3, and 4. l 5: I

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! With the measured overall integrated containment leakage rate exceeding 0.75 i

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L., or the measured combined leakage rate for all penetrations and valves subject to Type B and C tests exceeding 0.60 L., or the combined bypass

, leakage rate exceeding 0.042 L., restore the overall integrated leakage rate j to less than 0.75 L , the combined leakage rate for all penetrations subject j

to Type B and C tests to less than 0.60 L., and the combined bypass leakage '

rate to less than 0.042 L, prior to increasing the Reactor Coolant System l l

temperature above 200*F. ,

l SURVEILLANCE REQUIREMENTS .,

! 4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be detemined in conformance with the criteria

specified in Appendix J of 10 CFR Part 50 using methods and provisions of ANSI l N45.4-1972 (Total Time Nethod) and/or ANSI /ANS 56.8-1981 (Nass Point Nethod):

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a. Three Type A tests (Overall Integrated Containment Leakage Rate) ;

i shall be conducted at ap)roximately equal intervals during shutdown

at a pressure not less tian P., 53.27 psia (38.57 psig), during each '

10-year service period.* l

b. If any periodic Type A test fails to meet 0.75 L., the test schedule i for subsequent Type A tests shall be reviewed and approved by the i Commission. If two consecutive Type A tests fail to meet 0.75 L., a 1 Type A test shall be perfonned at least every 18 months until two

] consecutive Type A tests meet 0.75 L, at which time the above test schedule may be resumed;

The third Type A test will be conducted during the sixth refueling outage. As a result, the duration of the first 10-year service period will be extended to l the end of the sixth refueling outage. !

MILLSTONE - IRIIT 3 3/4 6-2 Amendment No. pp, 77, pf, JJJ, esos

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CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) __

1

2) Verifying, within 31 days after ren) val, that a laboratory analysis of a representative carbon sa'nple obtained in accord- '

ance with Regulatory Position C.6.b of Regulatory Guide 1.52,

' Revision 2, March 1978,* meets the laboratory testing criteria

of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-l sion 2, March 1978,* for a methyl iodide penetration of less 4

than 0.175%; and l 3) Verifying a system flow rate of 7600 cfm to 9800 cfm during i system operation when tested in accordance with ANSI N510-1980.

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c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation, by verifying, within 31 days after removal that a laboratory analysis of a repre-i sentative carbon sample obtained in accordance with Regulatory

Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,*

]

meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978,* for a methyl iodide penetration of less than 0.175%:

d. At least once per 18 months by:

1) Verifying that the pressure dro across the combined HEPA filters and charcoal adsorber b nks is less than 6.25 inches 1 Water Gauge while operating the system at a flow rate of 7600 cfm to 9800 cfm,

2) Verifying that the system starts on a Safety Injection test signal, and

3) Verifying that the heaters dissipate 50 5 kW when tested in accordance with ANSI N510-1980.

ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

MILLSTONE - UNIT 3 3/4 6-20 Amendment No. 7, 77, 77,

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CONTAINNENT SYSTEMS SECONDARY CONTAINNENT LINITING CONDITION FOR OPERATION 3.6.6.2 Secondary Containment shall be OPERABLE. l APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With Secondary Containment inoperable, restore Secondary Containment to OPERABLE l status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIRENENT 4.6.6.2.1 OPERABILITY of Secondary Containment shall be demonstrated at least l once per 31 days by verifying that each door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

4.6.6.2.2 At least once per 18 months, verify each Supplementary Leak Collection and Release System produces a negative pressure of greater than or equal to 0.4 inch water gauge in the Auxiliary Building at 24'-6" elevation within 120 seconds after a start signal.

NILLSTONE - UNIT 3 3/4 6-22 Amendment No. 77, Jpp, 03M

O e CONTAINNENT SYSTEMS SECONDARY.CONTAINNENT STRUCTURAL INTEGRITY l LIMITING CONDITION FOR OPERATION 3.6.6.3 The structural integrity of the Secondary Containment shall be maintained l at a level consistent with the acceptance criteria in Specification 4.6.6.3.

APPLICABILITY: N0 DES 1, 2, 3, and 4.

ACTION:

With the structural integrity of the Secondary Containment not conforming to the above requirements, restore the structural integrity to within the limits within hours or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIRENENT 4.6.6.3 The structural integrity of the Secondary Containment shall be determined l during the shutdown for each Type A containment leakage rate test (reference Specifica-tion 4.6.1.2) by a visual inspection of the exposed accessible interior and exterior surfaces of the Secondary Containment and verifying no apparent changes in appearance l of the concrete surfaces or other abnormal degradation. Any abnormal degradation of l the Secondary Containment detected during the above required inspections shall be l reported to the Commission in a Special Report pursuant to Specification 6.9.2 within l 15 days.

i 3/4 6-23 Amendment No. 77 Jpp, NI}LSTONE-UNIT 3 I

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i CONTAINMENT SYSTEMS BASES 3/4.6.6 SECONDARY CONTAINMENT 3/4.6.6.1 SUPPLEMENTARY LEAK COLLECTION AND RELEASE SYSTEM Backaround The OPERABILITY of the Supplementary Leak Collection and Release System (SLCRS) ensures that radioactive materials that leak from the primary contain- ,

ment into the Secondary Containment following a Design Basis Accident (DBA) are filtered out and adsorbed prior to any release to the environment.

Aeolicable Safety Analyses The SLCRS design basis is established by the consequences of the limiting DBA, which is a LOCA. The accident analysis assumes that only one train of the SLCRS and one train of the auxiliary building filter system is functional due to a single failure that disables the other train. The accident analysis accounts for the reduction of the airborne radioactive material provided by the remaining one train of this filtration system. The amount of fission products available for release from the containment is ]

determined for a LOCA.

The SLCRS is not normally in operation. The SLCRS starts on a SIS signal. The modeled SLCRS actuation in the rafety analysis (the Millstone 3 FSAR Chapter 15, Section 15.6) is based upon a worst-case response time following an SI initiated at the limiting setpoint. One train of the SLCRS in conjunction with the Auxiliary Building Filter (ABF) system is capable of drawing a negative pressure (0.4 inches water gauge at the auxiliary building 24'6" elevation) within 120 seconds after a LOCA. This time includes diesel generator startup and sequencing time, system startup time, and time for the system to attain the required negative pressure after starting.

l M[gLSTONE-UNIT 3 8 3/4 6-4 Amendment No. 77,

l CONTAIMENT SYSTEMS i

BASES

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3/4.6.6.1 SUPPLEMENTARY LEAK COLLECTION AND RELEASE SYSTEM (Continued) i LCD

! In the event of a DBA, one SLCRS is required to provide the minimum i postulated iodine removal assumed in the safety analysis. Two trains of the 3

SLCRS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single-active failure. The

SLCRS works in conjunction with the ABF system. Inoperability of one train of ;

the ABF system also results in inoperability of the corresponding train of the i SLCRS. Therefore, whenever LC0 3.7.9 is entered due to the ABF train A (B)

being inoperable, LCO 3.6.6.1 must be entered due to the SLCRS train A (B) being inoperable.

s When a SLCRS LC0 is not met, it is not necessary to declare the 4 secondary contcisiment inoperable. However, in this event, it is necessary to

! determine that a loss of safety function does not ext:t. A loss of safety 2 function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed.

Anolicability

! In MODES 1, 2, 3, and 4, a DBA could lead to a fission product release l to containment that leaks to the secondary containment. The large break LOCA, l l on which this system's design is based, is a full-power event. Less severe LOCAs and leakage still require the system to be OPERABLE throughout these j MODES. The probability and severity of a LOCA decrease as core power and i

reactor coolant system pressure decrease. With the reactor shut down, the i probability of release of radioactivity resulting from such an accident is low.

i l In MODES 5 and 6, the probability and consequences of a DBA are low due ,

to the pressure and temperature limitations in these MODES. Under these i j conditions, the SLCRS is not required to be OPERABLE. !

ACTIONS With one SLCRS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The operable train is capable of providing 100 percent of the iodine removal needs for a DBA. The 7-day Completion Time is based on consideration of such factors as the reliability of the OPERABLE redundant SLCRS train and the low probability of a DBA occurring during this period. The Completion Time is adequate to make most repairs. If the SLCRS

. cannot be restored to OPERABLE status within the required Completion Time, the i plant must be brought to a MODE in which the LC0 does not apply. To achieve

' this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and l MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed Completion Times are 4

reasonable, based on operating experience, to reach the required plant conditions from full-power conditions in an orderly manner and without challenging plant systems.

. MILLSTONE - UNIT 3 0305 83/46-5 Amendment No. 57, 1

CONTAINNENT SYSTENS BASES 3/4.6.6.2 SECONDARY CONTAINMENT The Secondary Containment is comprised of the containment enclosure building and all contiguous buildings (main steam valve building [ partially],

engineering safety features building [ partially), hydrogen recombiner building (partially), and auxiliary building). The Secondary Containment shall exist when:

a. Each door in each access opening is closed except when the access opening is being used for normal transit entry and exit,

b. The sealing mechanism associated with each penetration (e.g.,

welds, bellows, or 0-rings) is OPERABLE.

Secondary Containment ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to thosa leakage paths and associated leak rates assumed in the safety analyses. TL"s restriction, in conjunction with operation of the Supplementary ok Collection and Release System, and Auxiliary Building Filter System will limit the SITE B0UNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.

The SLCRS and the ABF fans and filtration units are located in the auxiliary building. The SLCRS is described in the Millstone Unit No. 3 FSAR, j Section 6.2.3.

In order to ensure a negative pressure in all areas within the Secondary Containment under most meteorological conditions, the negative pressure acceptance criterion at the measured location (i.e., 24'6" elevation in the auxiliary building) is 0.4 inches water gauge.

LC.Q The Secondary Containment OPERABILITY must be maintained to ensure proper operation of the SLCRS and the auxiliary building filter system and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.

Acolicability Maintaining Secondary Containment OPERABILITY prevents leakage of 4

radioactive material from the Secondary Containment. Radioactive material may l enter the Secondary Containment from the containment following a LOCA. <

Therefore, Secondary Containment is required in MODES 1, 2, 3, and 4 when a design basis accident such as a LOCA could release radioactive material to the containment atmosphere.

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CONTAllBIENT SYSTENS i LASES

! 3/4.6.6.2 SECONDARY CONTAINMENT (continued)

. .In MODES 5 and 6, the probability and consequences of a DBA are low due l to the RCS temperature and pressure limitation in these MODES. Therefore, i Secondary Containment is not required in MODES 5 and 6.

l I. ACTIONS 4

In the event Secondary Containment OPERABILITY is not maintained, i Secondary Containment OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Twenty- :

four hours is a reasonable Completion Time considering the limited leakage l 1 design of containment and the low probability of a DBA occurring during this !

i time period. Therefore, it is considered that there exists no loss of safety ;

i function while in the ACTION Statement. ;

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Inoperability of the Secondary Containment does not make the SLCRS fans ;

j and filters inoperable. Therefore, while in this Action Statement solely due i to inoperability of the Secondary Containment, the conditions and required i actions associated with Specification 3.6.6.1 (i.e., Supplementary Leak

! Collection and Release System) are not required to be entered. If the i Secondary Containment OPERABILITY cannot be restored to OPERABLE status within

{ the required completion time, the plant must be brought to a MODE in which the i

! LC0 does not apply. To achieve this status, the plant must be brought to at ;

least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The !

4 allowed Completion Times are reasonable, based on operating experience, to 1

, reach the required plant conditions from full-power conditions in an orderly i 3 manner and without challenging plant systems. l Surveillance Reouirements i'

4.6.6.2.1 Maintaining Secondary Containment OPERABILITY requires maintaining each :

door in each access opening in a closed position except when the access opening is being used for normal entry and exit. The normal time allowed for passage of equipment and personnel through each access opening at a time is !

defined 4s no more than 5 minutes. The access opening shall not be blocked open. During this time, it is not considered necessary to enter the action statement. A 5-minute time is considered acceptable since the access opening ;

can be quickly closed without special provisions and the probability of occurrence of a DBA concurrent with equipment and/or personnel transit time of e 5 minutes is low.

i The 31-day frequency for this surveillance is based on engineering.

Judgment and is considered adequate in view of the other indications of access l opening status that are available to the operator.

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CONTAINMENT SYSTEMS BASES 3/4.6.6.2 SECONDARY CONTAINMENT (continued) 4.6.6.2.2 The ability of a SLCRS to produce the required negative pressure during the test operation within the required time provides assurance that the Secondary Containment is adequately sealed.

With the SLCRS in postaccident configuration, the required negative pressure in the Secondary Containment is achieved in 110 seconds from the time of simulated emergency diesel generator breaker closure. Time delays of dampers and logic delays must be accounted for in this surveillance. The time to achieve the required negative pressure is 120 seconds, with a loss-of-offsite power coincident with a SIS. The surveillance verifies that one train of SLCRS in conjunction with the ABF system will produce a negative pressure of 0.4 inches water gauge at the auxiliary building 24'6" elevation relative to the outside atmosphere in the Secondary Containment. For the purpose of this surveillance, pressure measurements will be made at the 24'6" elevation in the auxiliary building. This single location is considered to be adequate and representative of the entire Secondary Containment due to the large cross-section of the air passages which interconnect the various buildings within the Secondary Containment. In order to ensure a negative pressure in all areas inside the Secondary Containment under most meteorological conditions, the negative pressure acceptance criterion at the measured location is O.4 inch water gauge. It is recognized that there will be an occasional meteorological condition under which slightly positive pressure may exist at some localized portions of the boundary (e.g., the upper elevations on the down-wind side of a building). For example, a very low outside temperature combined with a moderate wind speed could cause a slightly positive pressure at the upper elevations of the containment enclosure building on the leeward face. The probability of occurrence of meteorological conditions which could result in such a positive differential pressure condition in the upper levels of the enclosure building has been estimated to be less than 2% of the time.

The probability of wind speed within the necessary moderate band, combined with the probability of extreme low temperature, combined with the l small portion of the boundary affected, combined with the low probability of airborne radioactive material migrating to the upper levels ensures that the overall effect on the design basis dose calculations is insignificant.

The SLCRS system and fan sizing was based on an estimated infiltration i rate. The fan flow rates are verified within a minimum and maximum on a 1 monthly basis. Initial testing verified that the drawdown criterion was met i at the lowest acceptable flow rate. The new standard Technical Specification (NUREG-1431) 3.6.6.2 surveillance requirement requires that the drawdown

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CONTAINNENT SYSTEMS BASES i

3/4.6.6.2 SECONDARY CONTAINMENT (continued)

I criterion be met while not exceeding a maximum flow rate. It is assumed that the purpose of this flow limit is to ensure that adequate' attention is given i to maintain the SLCRS boundary integrity and not using excess system capacity

to cover for boundary degradation.

The SLCRS system was designed with minimal margin and, therefore, does not have excess capacity that can be substituted for boundary integrity.

Additionally, since SLCRS fan flow rates are verified to be acceptable on a more frequent basis than the drawdown test surveillance, and by means of 1 previcus testing the minimum flow rate is acceptable, verifying a flow rate ,

during the drawdown test would not provide an added benefit. Historical SLCRS -

flow measurements show a lack of repeatability associated with the inaccura- ;

cies of air flow measurement. As a result, the more reliable verification of l system performance is the actual negative pressure generated by the drawdown t test and a measured flow rate would add little. l l

3/4.6.6.3 SECONDARY CONTAINMENT STRUCTURAL INTEGRITY l This limitation ensures that the structural integrity of the Secondary i Containment will be maintained comparable to the original design standards for i the life of the facility. Structural integrity is required to provide a i secondary boundary surrounding the primary containment that can be maintained ;

at a negative pressure during accident conditions. A visual inspection is t sufficient to demonstrate this capability.

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I MjgLSTONE-UNIT 3 8 3/4 6-10 Amendment No. 57, 9

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