ML20096E595

Proposed Tech Specs Re Containment Leak Rate Testing Requirements of 10CFR50 App J,Option B

ML20096E595
Person / Time
Site:	Catawba
Issue date:	01/12/1996
From:	DUKE POWER CO.
To:
Shared Package
ML20096E591	List: ML20096E587 ML20096E595
References
NUDOCS 9601220281
Download: ML20096E595 (14)

Text

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A>o GHAMI6is 10 Th 16 PASG3

) 3/4.6' CONTAINMENT SYSTEMS g jpg/pM7/CA) 3/4.6.1 PRIMARY CONTAINMENT _ g/[] f 4

CONTAINMENT INTEGRITY ~

LIMITING CONDITION FOR OPERATION i

- 3. 6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

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

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within i

. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or.be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />'and in COLD l j- SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ,

I t

SURVEILLANCE REQUIREMENTS i

4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated: -

At least once per 31 days by verifying that all penetrations

• not  !

.') a.

capable of being closed by OPERABLE containment automatic isolation l

valves and required to be closed during accident conditions are  !

-closed by valves, blind flanges, or deactivated automatic valves 1

' secured in their positions, except as provided in Table 3.6-2 of l Specification 3.6.3;

b. By verifying that each containment air lock is in compliance with 4

i the requirements of Specification 3.6.1.3; and

c. After each closing of each penetration subject to Type B testing,

' except the containment air locks, if opened following a Type A or B test, by leak rate testing the seal with gas at a pressure not less than P , 14.68 psig, and verifying that when the measured leakage rate forth$sesealsisaddedtotheleakageratesdeterminedpursuantto Specification 4.6.1.2d. for all other Type B and C penetrations, the combined leakage rate is less than to 0.60 L,.

m Except valves, blind flanges, and deactivated automatic valves which are located inside the annulus or the containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be i

verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

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9601220281 960112 '

PDR ADOCK 05000413 P PDR

, CATAWBA - UNITS 1 & 2: 3/4 6-1 1

s CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE k, ~#

LIMITING CONDITION FOR OPERATION

3. 6.1. 2 Containment leakage rates shall be limited to:

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a. An overall integrated leakage rate ofg 15- Less than or equal to L,, 0.30% by weight of the containment l air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P,,14.68 psig.-ee-1 2) (Unit 1) Less tbn or eq"=1 to L ,4r122%

t by weiwid vf4Ae.

caat h..;nt &ir per 2? M ur: et & i- a n.ed pres =wre ef D g, i.20 psie

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

and

c. A combined bypass leakage rate of less than 0.07 L, for aH penetrations identified in Table 3.6-1 as secondary containment /

bypass leakage paths when pressurized to P .

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

ACTION:

With: (a) the measured overall integrated containment leakage rate exceeding 0.75 L, w ^.75 L t ' "

'- r (b) the measured combined leakage rate for all l penetrations and valves subject to Types B and C tests exceeding 0.60 L,, or  !

(c) the combined bypass leakage rate exceeding 0.07 L,, restore the overall integrated leakage rate to less than 0.75 L, c- h..-; nan ^.?E-4 t' " ;EEI

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and the combined leakage rate for all penetrations and valves subject to Type B and C tests to less than 0.60 L,, and the combined bypass leakage rate to less than 0.07 L, prior,to increasing the Reactor Coolant System temperature above 200*F.

SURVEILLANCE REQUIREMENTS

/Al ACMMM WM i y A

4. 6.1. 2 The containment leakage raten shall be demonstrated at We E '- 5 test schedule -=d n:. h determined in conformance with W sMM-

- +1:d % Appendix J of 10 CFR Part 5 using the methods an1 provisions 04-#61 ~1

.JR5J-1072 ei 4hwrrs pkt ::.thod; yM&ULATO$60lW l k

,o n\0u 0) $GPTff1 CATAWBA . UNITS 1 & 2 3/4 6-2 Amendment No. Q(Unit 1 Amendment No. y (Unit 2) i M ,

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CONTA NMENT SYSTEMS *

! SURVEILLANCE REQUIREMENTS (Continued) israM Intanentaa fantm4- bt I amirmaa. Data)

3. .g{ an + b -anth M arom K a N o .k Jaol. J

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or UnY 1) at ~~ 7.'34 psig,"during hall be n-eh l

Q (The t ird tesk f each set d y for t 10-year lant inser ice l

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b. ~gQg r 0.75 ( or (Unit 1) l .ibse o meet t Type eithe % ts sha f two consecutive be eA 3 emaission.

75 L,, pe A t 4e or 8(Unit months unt two cons utive at which ime 1

L or it 1) 0.75

• 4 the above t%st schedule may A , resume

c. The accuracy of each Type A test shall be verified by a supplemental , ..

tes  :.% pJ ActcRMJCE t>JITH (dEGWMOC'f GehDE I.Iff,5GPTEh6bt i.1 V

+km ....1=_.-

i li fanFirme the neceirmeu af tha + met ~'~' bu unr4#u4=a +k+'

ntal testi result [i.,,minus the s'um U tielypTA a'nd l sup osed leak, L,, is equal to or less than 0. , or 1 (Unit 1) . L,;

to esta accurately the change in

! 2) Has a duration suff c est and the supplemental test; i

leakage rate between the and  !

.L Requires th e rate at which gas is injec nto the con-2

3) bled from the containment during the s mental tain l

s between 0.75 L, and 1.25 L, or (Unit 1) 0.75 L, a i h25 L,.

d. Type B and C tests shall be conducted with gas at a pressure not less ,' li 14.68 psig, at intervals no greater than 24 months except

than for te P's,ts involving: ,

1 4 1) Air locks,

2) Purge supply and exhaust isolation valves with resilient material seals, and j 3) Dual-ply bellows assemblies on containment penetrations between the containment building and the annulus.

rante o exten is in val

• For C awba Uni a one-ti change i i

tween t second te (performe 91) and ie thi test to i 10 hs.

4-uring the 10-yea ISI refue ng outa this te will not performe i Als exemption to 10 CFR , Append J.

i . This r resents 1

i CATAWBA UNITS 1 & 2 3/4 6-3 Amendment No. (Unit 1)

Amendment No (Unit 2) y

3/4.6 CONTAINMENT SYSTEMS

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BASES 3/4.6.1 PRIMARY CONTAINMENT 4

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 safety analyses. This restric-tion, in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.

3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total contain-

- ment leakage volume will not exceed the value assumed in the safety analyses i at the peak accident pressure. P,. As an added conservatism, the 2:n_. ;d AS-LEFT overall integrated leac , ca'ce is further limited to less than or equal to

0. 75 L, tmmes46 ' ,

-- W"n hr'r.g perh= ace c' t.t periedic t::t:

to account for possible degradation of the containment leakage barriers

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between leakage tests.

The surveillance testing for measuring leakage rates consistent with the requirements of Appendix J of 10 CFR Part 50j O87'/@ d 3/4.6.1.3 CONTAINMENT AIR LOCKS

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The limitations on closure and leak rate for the containment 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.

3/4.6.1.4 INTERNAL PRES 5URE The limitations on containment internal pressure ensure that: (1) the containment structure is prevented from exceeding its design negative pressure differential with respect to the outside atmosphere of 1.5 psig, and (2) the containment peak pressure does not exceed the design pressure of 15 psig during LOCA conditions.

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CATAWBA - UNITS 1 & 2 B 3/4 6-1

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

a. An overall integrated leakage rate of less than or equal to L,, 0.305:

by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P,,14.68 psig.

c

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

c. A combined bypass leakage rate of less than 0.07a L for all pene-trations identified in Table 3.6-1 as secondary containment bypass leakage paths when pressurized to P,.

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

ACTION:

l With: (a) the measured overall integrated containment leakage rate exceeding l 0.75 L,, or (b) the measured combined leakage rate for all penetrations and

valves subject to Types B and C tests exceeding 0.60 L,, or (c) the combined i

, restore the overall integrated leakage bypass rate to less than 0.75 L, and the com L bined leakage rate for all penetrations leakage rate exceeding 0.07 4 and valves subject to Type B and C tests to less than 0.60 La , and the combined bypass leakage rate to less than 0.07 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 in accordance with 10 CFR 50.54(o) at a test schedule determined in conformance with Appendix J of 10 CFR Part 50, Option B, using the methods and provisions of ,

Regulatory Guide 1.163, September, 1995.

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CATAWBA - UNIT 1 3/4 6-2 Amendment No.

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

a. Deleted

b. Deleted

c. The accuracy of each Type A test shall be verified by a supplemental test in accordance with Regulatory Guide 1.163, September,1995.

d. Type B and C tests shall be conducted with gas at a pressure not less than P ,14.68 psig, at intervals no greater than 24 months except for tests involving: ,

Air locks, 1)

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

3) Dual-ply bellows assemblies on containment penetrations between the containment building and the annulus.

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CATAWBA - UNIT 1 3/4 6-3 Amendment No.

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3/4.6 CONTAINMENT SYSTEMS BASES 4

3/_4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY 1

Primary CONTAINMENT INTEGRITY ensures that the release of radioactive i materials from the containment atmosphere will be restricted to those leakage

paths and associated leak rates assumed in the safety analyses. This restric-tion, in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.

3/4.6.1.2 CONTAINMENT LEAKAGE

' The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the safety

analyses at the peak accident pressure, P . As an added conservatism, the as-left overall integrated leakage rate is f0rther limited to less than or equal

to 0.75 L to account for possible degradation of the containment leakage

barriers $etweenleakagetests.

The surveillance testing for measuring leakage rates is consistent with the requirements of Appendix J of 10 CFR Part 50, Option B.

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3/4.6.1.3 CONTAINMENT AIR LOCKS i '

The limitations on closure and leak rate for the containment 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 J the overall air lock leakage will not become excessive due to seal damage during the intervals between air lock leakage tests.

3/4.6.1.4 INTERNAL PRESSURE

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The limitations on containment internal pressure ensure that: (1) the containment structure differential with respectistoprevented from the outside exceedingofits1.5 atmosphere design psig,negative p)ressure and (2 the containment peak pressure does not exceed the design pressure of 15 psig during LOCA conditions.

CATAWBA - UNIT 1 B 3/4 6-1 i

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

a. An overall integrated leakage rate of less than or equal to L,, 0.30%

by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P,,14.68 psig.

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

c. A combined bypass leakage rate of less than 0.07 L, for all pene-trations identified in Table 3.6-1 as secondary containment bypass leakage paths when pressurized to P,.

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

ACTION:

With: (a) the measured overall integrated containment leakage rate exceeding 0.75 L , or (b) the measured combined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L,, or (c) the combined restore the overall integrated leakage bypass rate to less than 0.75 L,, and the com ,bined leakage rate for all penetrations leakage rate exceeding 0.07 L and valves subject to Type B and C tests to less than 0.60 L,, and the combined bypass leakage rate to less than 0.07 L, prior to increasing the Reactor Coolant System temperature above 200*F.

SURVEILLANCE RE0VIREMENTS 4.6.1.2 The containment leakage rates shall be demonstrated in accordance with 10 CFR 50.54(o) at a test schedule determined in conformance with Appendix J of 10 CFR Part 50, Option B, using the methods and provisions of Regulatory Guide 1.163, September,1995.

CATAWBA - UNIT 2 3/4 6-2 Amendment No.

4 i

CONTAINMENT SYSTEMS i

l SURVEILLANCE REQUIREMENTS (Continued)

a. Deleted

b. Deleted i c. The accuracy of each Type A test shall be verified by a supplemental test in accordance with Regulatory Guide 1.163, September,1995.

d. Type B and C tests shall be conducted with gas at a pressure not less than P , 14.68 psig, at intervals no greater than 24 months except forte $tsinvolving:

i Air locks, 1) l ,' 2) Purge supply and exhaust isolation valves with resilient

material seals, and 4

l 3) Dual-ply bellows assemblies on containment penetrations between 4 the containment building and the annulus. ,

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T i

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e 4

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1 CATAWBA - UNIT 2 3/4 6-3 Amendment No.

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3/4.6 CONTAINMENT SYSTEMS i

BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.'1 CONTAINMENT INTEGRITY I Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage 4 paths and associated leak rates assumed in the safety analyses. This restric-tion, in conjunction with the leakage rate limitation, will limit the SITE l BOUNDARY radiation doses to within the dose guideliae values of 10 CFR l

Part 100 during accident conditions. j 3/4.6.1.2 CONTAINMENT LEAKAGE l i

~

The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the safety

, analyses at the peak accident pressure, P . As an added conservatism, the as-

' left overall integrated leakage rate is f0rther limited to less than or equal to 0.75 L to account for possible degradation of the containment leakage

barriers $etweenleakagetests.

The surveillance testing for measuring leakage rates is consistent with the requirements of Appendix J of 10 CFR Part 50, Option B. ,

l j 3/4.6.1.3 CONTAINMENT AIR LOCKS The limitations on closure and leak rate for the containment air locks are required to meet the restrictions on CONTAINMENT INTEGRITY and containment 4

leak rate. Surveillance testing of the air lock seals provide assurance that i the overall air lock leakage will not become excessive due to seal damage

. during the intervals between air lock leakage tests.

j 3/4.6.1.4 INTERNAL PRESSURE 4

The limitations on containment internal pressure ensure that: (1) the 4

containment structure is prevented from exceeding its design negative pressure differential with respect to the outside atmosphere of 1.5 psig, and (2) the j containment peak pressure does not exceed the design pressure of 15 psig during LOCA conditions.

i CATAWBA.- UNIT 2 B 3/4 6-1 1

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.. 8 Attachment II Description of and Justification for Technical Specification Change Description of Changes The changes included in Attachment I will implement the NRC's revision to 10 CFR 50, Appendix J, which became effective on October 26, 1995. The revision to the regulation represents a shift away from prescriptive testing requirements in Appendix J,

. Option A, to a performance-based approach (Option B).

Specifically, upon completion of two' consecutive successful Type A tests, the licensee may extend the test interval up to 10 years

- between Type A tests. (Option B also provides for test interval extensions for Type B and C testing, but these changes are not being requested at this time.)

The changes requested herein include:

Specification 3.6.1.2.a.2), which spec'ifies requirements for i reduced-pressure testing, is being deleted. Reduced-pressure

testing is not acceptable under the new (Option B) rule. i Accordingly, references to reduced-pressure acceptance criteria 2

are also deleted from the ACTION statement.

l Surveillance Requirement 4.6.1.2 is being revised to refer to the requirement in 10 CFR 50.54(o) that containment testing be performed pursuant to Appendix J; the reference to Appendix J that currently exists in SR 4.6.1.2 will now refer to Option B of the Appendix; a reference to Regulatory Guide 1.163, September, 1995, is being added. RG 1.163 is the implementation document for the new rule.

SR 4.6.1.2 a and b. are deleted. The test schedule is now determined based upon the criteria of the implementing documents.

In SR 4.6.1.2.c, a reference is added to RG 1.163, dated i September, 1995, as the implementing document; and redundant and/or obsolete requirements (c.1), 2), and 3)) are deleted.

A footnote at the bottom of page 3.6-3, which refers to a deferral of a CLRT for Catawba Unit 1, is deleted. With the approval of this proposed amendment, the test will become unnecessary.

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Attachment II, continued A change to BASIS 3/4.6.1.2 specifies that the as-left containment leakage shall be less than or equal to .75 L., to account for possible degradation of the containment between tests. Also, a reference to a reduced-pressure test criterion was deleted, and a reference to Option B of Appendix J was added.

Technical Justification The proposed changes are based on approved guidance documents from the NRC and Nuclear Energy Institute (NEI), including NEI 94-01, dated July 26, 1995; Regulatory Guide 1.163, dated September, 1995; and sample Improved Standard Technical Specifications (ISTS)

'- ' developed by NEI, with NRC cooperation. The sample ISTS provided guidance on the scope of changes that the NRC expects to see from each of the utilities who elect to pursue Option B. The changes presented in this application meet the intent of the changes, relative to Type A testing, that have been approved in concept by the NRC. The NRC has determined that the industry guideline (NEI 94-01) referenced in the Regulatory Guide, with some exceptions, is an acceptable means of demonstrating compliance with the requirements of Option B. Duke Power intends to comply with the provisions of the NEI document, except as modified by the Regulatory Guide.

The as-found acceptance criterion for Type A tests, a., as specified in TS 3.6.1.2, has not changed, nor has the requirement that the containment leakage be less than or equal to .75 La before entering a mode in which containment integrity is required.

Deleting the details of the test program from TSs, and providing a reference to the guidance document (RG 1.163) is consistent with the recommendations of the Regulatory Guide.

The change in the test interval, based on the performance of the containment structure in previous tests, has been determined by the NRC's own analysis, presented in NUREG-1493, to have a minimal i impact on safety. Catawba has achieved excellent results in l previous CLRTs for both units.

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Attachment III No Significant Hazards Analysis The following analysis is presented, pursuant to 10 CFR 50.91, to demonstrate.that the proposed change will not create a Significant Hazard Consideration.

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

Containment leak rate testing is not an initiator of any accident; the proposed change does not affect reactor operations or accident analysis, and has no significant radiological consequences.

Therefore, this proposed change will not involve an increase in the probability or consequences of any previously-evaluated accident.

2. The proposed change will not create the possibility of any new accident not previously evaluated.

1 The proposed change does not affect normal plant operations or configuration, nor does it affect leak rate test methods. The test j history at Catawba (no ILRT failures) provides continued assurance of the leak tightness of the containment structure.

3. There is no significant reduction in a margin of safety.

) The proposed changes are based on NRC-accepted provisions, and 1

maintain necessary levels of reliability of containment integrity.

The performanced-based approach to leakage rate testing recognizes that historically good results of containment testing provide appropriate assurance of future containment integrity; this supports the conclusion that the impact on the health and safety of the public as a result of extended test intervals is i negligible.

4 Based on the above, no significant hazards consideration is )

, created by the proposed change.

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I Attachment III, continued Environmental Assessment The proposed change has been evaluated to determine if any environmental impact would be created. The change is considered to' meet the criteria (presented in 10 CFR 51.22 (c) (9)) for categorical exclusion from the requirements for an environmental assessment, because:

A. As documented above, the change will create No Significant Hazards Consideration.

B. There is no change in the type, or significant increase in the amounts, of any effluent that may be released offsite.

The change will create no new mechanism by which effluents are released, and will provide continued assurances that leakage remains within the existing allowed leakage, L.,

C. There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed change will not change methods by which radioactive materials, including effluents, are handled, processed, or disposed of. Normal radiation levels within the nuclear station will not increase, and this change will not result in personnel spending additional time in radiation areas.

Therefore, there will be no increase in individual or cumulative radiation exposure.

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