Text

Proposed Tech Specs 4.6.1.2.a Re Containment Sys
	ML20097F899
Person / Time
Site:	Callaway
Issue date:	02/04/1996
From:	; UNION ELECTRIC CO.
To:	;
Shared Package
ML20097F892	List: ML20097F889; ML20097F899;
References
	NUDOCS 9602200227
	Download: ML20097F899 (23)
	v • d • e

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3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABIL111: MODES 1, 2, 3, and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY !

within I hour 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 l in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . l SURVEILLANCE REQUIREMENTS 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated: .

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a. At least once per 31 days by verifying that all penetrations

not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except as provided in Table 3.6-1 of Specification 3.6.3;

b. By verifying that each containment air lock is in compliance with the requirements of S ecification 3.6.1.3; i

c. ft r each losing f each pe tration su ject.t Type B testing, ex ept th contai ent air 1 ks, if ope ed fol wing a ype A r test, y leak te testin the seal th gas t a pr sure at i

less t nP 4 .1 psig, a d verifyin that w n the asure leaka e rate ,f r these s is is adde to the eakage rates det mined p'u suant to ecificati 4.6.1. .d ' for 11 ot r Ty B and O penetrati s, the co. ined lea agp ra e is less than (' '

O.50 L,; i We /efedx J

d. By performing containment leakage rate testingyeept for

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e. By verifying containment structural integrity in accordance with the Containment Tendon Surveillance Program of Specifica-tion 6.8.5.c.

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

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

CALLAWAY - UNIT 1 3/4 6-1 Amendment No.-1?, 52 %&

9602200227 960209 PDR P ADOCK 05000483 PDR ,,

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,, , 4- ' -v CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS

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LIMITING CONDITION FOR OPERAT30N l

! 3. 6.1. 3 N W Each containment air lock shall be OPERABLE with)( j

p foth doors closed except when the air lock is being used for normal transit entry and exits through the containment, then at least one lo door s all be c gsed, end y l % A a

vera a kag of )[s/than/o"r/qua/ to/.05%

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

ACTION: -

a. With one containment air lock door inoperable:

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1. Maintain at least the OPERABLE air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or lock the OPERABLE air lock door closed,

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2. Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be locked closed at least once per l , 31 days ,

3. Othervise, 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 , and

4. The provisions of Specification 3.0.4 are not applicable.

b. With the containment air lock inoperable, except as the result of'an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status 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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CALLAWAY - UNIT 1 3/4 6-4 Amendment No. M =

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CONTAINMENT SYSTEMS

, SURVEILLANCE REOUIREMENTS I

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4. 6.1. 3 Each containment air lock shall be demonstrated OPERABLE- 1 N

a. Wit in 72 our followin eac closing exce when e air ock i be'ng us d f multiple entr'es, the : 1ee one et 72 ours by v rifyi g th the se lea age is 1 s tha 0.00 L, a s eterm ed r } by pr isio flow me urem ts wheymeasurj!d for ft leas 30 se nds wit the lume be en t seals /at a ep6stant f ressu of g ater

,! th . or val to psig,

b. By con 1 eting ov rall fa r lock akage ests at not less anfP,, !

48.1 sig, ancVverify(ng the overall air loc eakage rete is/within l imit:

,, its 1 At 1 ast once er 6 m nths,# nd c) Pr or to es ablish g CONT NMENT I 4EGRITY wj.HIn main /en ce s b.een p rform en th air loc that cou1( affecVth air f ock seal ng c ity.

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[. At least once per 6 months by verifying that only one door in each air lock can be opened at a time.

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a. By vaifpg laKye rdes in sccordance

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ihe prov 'sions of Sp ci fip6tioy4. .2 arj/ notj(pplifab}(.

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. sr resen CF Par s an xempgiongoA enc % J, Taragdph/III.0[. (b[ii),/f p A_ 4 CALLAVAY - UNIT 1 3/4 6-5 '

Amendment No. W

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ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

f. Radiolooical Environmental Monitorine Procram (Continued)

3) Participation.in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the -

measurements of radioactive materials in environmental sample pgggr A matrices are performed as part of the quality assurance program or environmental monitoring.

.. T e following programs, relocated from the Technical Specifications to FSAR Chapter 16, shall be implemented and maintained:

a. Exolosive Gas and Storace Tank Radioactivity Monitorino Procram This program provides controls for potentially explosive gas mixtures contained in the WASTE GAS HOLDUP SYSTEM, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The program shall include:

1. The limits for concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM and a surveillance program to ensure the limits are maintained.

2. A surveillance program to ensure that the quantity of radioactivity contained in each gas storage tank is less than the amount that would result in a whole body exposure of 2 0.5 rem to a MEMBER OF THE PUBLIC at the nearest SITE BOUNDARY in the event of an uncontrolled release of the tanks' contents, consistent with Branch Technical Position ETSB 11-5, " Postulated Radioactive Releases due to Waste Gas System Leak or Failure," in NUREG-0800, July 1981. l

3. A surveillance program to ensure that the quantity of radioactivity contained in the following outdoor liquid radwaste tanks, that are not surrounded by liners, dikes, or walls capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste system, is less than the amount that would result in concentrations less than the limits of 10 CFR Part 20.1 -20.602, Appendix B.(redesignated at 56FR23391, May 21, 1991) at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA, in the event of an uncontrolled release of the tanks' contents:

a. Reactor Makeup Water Storage Tank,

b. Refueling Water Storage Tank,

c. Condensate Storage Tank, and

'l d. Outside temporary tanks, excluding demineralizer vessels '

__ / and the liner being used to solidify radioactive waste.

CALLAWAY - UNIT 1 6-19 Amendment No. 27, 50 +

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4 INSERT A

g. Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing 50, of the containment as required by 10 CFR 50.54(o) and 10 CFR Appendix.J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995.

The basispeak losscalculated of coolantcontainment accident, P.,internal pressure for the design is 48.1 psig.

The maximum allowable containment leakage rate, L., at P., shall be 0.20% of the containment air weight per day.

Leakage rate acceptance criteria are:

a.

Containment leakage rate acceptance criterion is 5 1.0 L.,

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L. for the Type B and C tests and s 0.75 L. for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is s 0.05 L.when tested at 2 P.;

2) For each door, leakage rate is s 0.005 L. when pressurized-to 2 10 psig.

The provisions of Technical Specification 4.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.

The provisions of Technical Specification 4.0.3 are applicable l

to the Containment Leakage Rate Testing Program.

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ATTACHMENT 2 TECHNICAL SPECIFICATION CHANGES (RE-TYPED)

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3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT

.C_ONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained. :

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

ACTION:

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"/ithout primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 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 CO SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS .

4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

4 a.

At least once per 31 days by verifying that all penetrations

not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by manual valves, blind flanges, or deactivated automatic valves

secured in their closed positions, except as provided in Table 3.6-1 of Specification 3.6.3; b.

By verifying that eacn containment air lock is in compliance with the requirements of Specification 3.6.1.3:

c. Deleted, d.

By performing containment leakage rate testing in accordance with the Containment and Leakage Rate Testing Program.

e.

By verifying containment structural integrity in accordance with the ContcSment Tendon Surveillance Program of Specification 6.8.5.c.

Except valves, blind flanges, and deactivated automatic valves which are located inside the containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

CALLAWAY - UNIT 1 3/4 6 1 Amendment No. 13, 62, 403 l

. 4 CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIMITING CONDITION FOR OPERATION '

3.6.1.3 Each containment air lock shall be OPERABLE with both doors closed except when the air lock is being used for normal transit entry through the containment, then at least one air lock door shall be closed.

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

ACTION:

a. With one containment air lock door inoperable:

1.

Maintain at least the OPERABLE air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or lock the OPERABLE air lock door closed, 2.

Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days.

3.

Otherwise, 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 , and 4.

The provisions of Specification 3.0.4 are not applicable.

b.

With the containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status 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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CALLAWAY - UNIT 1 3/4 6-4 Amendent No.13

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CONTAINMENT SYSTEMS i

SURVElLLANCE REQUIREMENTS 4

4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:

l a.

By verifying leakage rates in accordance with the Containment Leakage Rate Testing Program; and b.

At least once per 6 months by verifying that only one door in each air lock can be opened at a time.

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I CALLAWAY - UNIT 1 3/4 6-5 Amendent No.13

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ADMINISTRATIVE CONTROLS i

PROCEDURES AND PROGRAMS (Continued) f.

Radioloaical Environmental Monitorina Proaram (Continued)

3) Participation in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.'

g.

Containment Leakaoe Rate Testina Proaram A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 48.1 psig.

The maximum allowable containment leakage rate, L., at P., shall be 0.20% of the containment air weight per day.

Leakage rate acceptance criteria are:

a.

Containment leakags rate acceptance criterion is i 1.0 L..

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are 10.60 L.

for the Type B and C tests and 10.75 L. for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is 10.05 L. when tested at A P.;

2) For each door, leakage rate is S 0.005 L. when pressurized to 110 psig.

The provisions of Technical Specification 4.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.

The provisions of Technical Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

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CALLAWAY - UNIT 1 6-19 Amendment No. 27, 50, A 02,

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. l ApMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) l l

6.8.5 The following programs, relocated from the Technical Specifications to I FSAR Chapter 16, shall be implemented and maintained:

a. Exolosive Gas and Storaae Tank Radioactivity Monitorina Procram I This program provides controls for potentially explosive gas mixtures contained in the WASTE GAS HOLDUP SYSTEM, the quantity of j radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. i The program shallinclude:

1. The limits for concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM and a surveillance program to ensure the limits are maintained.

2.

A surveillance program to ensure that the quantity of radioactivity contained in each gas storage tank is less than the amount that would result in a whole body exposure of 2 0.5 rem to a MEMBER l

OF THE PUBLIC at the nearest SITE BOUNDARY in the event of '

an uncontrolled release of the tanks' contents, consistent with l Branch Technical Position ETSB 11-5, " Postulated Radioactive Releases due to Waste Gas System Leak or Failure," in NUREG-0800, July 1981. ,

I 3.

A surveillance program to ensure that the quantity of radioactivity i

contained in the following outdoor liquid radwaste tanks, that are not surrounded by liners, dikes, or walls capable of holding the

)

tanks' contents and that do not have tank overflows and ,

surrounding area drains connected to the liquid radwaste system, !

is less than the amount that would result in concentrations loss i than the limits of 10 CFR Part 20.1 - 20.602, Appendix B (redesignated at 56FR23391, May 21,1991) at the nearest i

! potable water supply and the nearest surface water supply in an UNRESTRICTED AREA,in the event of an uncontrolled release of the tanks' contents:

a. Reactor Makeup Water Storage Tank,

b. Refueling Water Storage Tank,

c. Condensate Storage Tank, and

d. Outside temporary tanks, excluding demineralizer vessels and the liner being used to solidify radioactive waste.

CALLAWAY - UNIT 1 6-19aa Amendment No. A 03

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ATTACHMENT 3 SAFETY EVALUATION l

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SAFETY EVALUATION 1

l This license amendment requests a revision to Technical Specification (TS) 3/4.6.1.1, " Containment Integrity," and 3/4.6.1.3, " Containment Air Locks" to implement performance l based leakage rate testing as permitted by 10 CFR 50, i Appendix J. TS 6.8.4 would be revised by the addition of the l leakage rate testing program description. These changes I support the implementation of performance based testing !

allowed by Appendix J, Option B for Type A, B and C l containment leak rate testing. 1 l

This proposed change is consistent with the revision to 10 l CFR 50, Appendix J as noticed in 60 FR 49495 dated September l 26, 1995. A similar request to partially implement Option B for Type B and C testing has been submitted by Georgia Power Company for Vogtle Electric Generating Plant.

Background

The purpose of Appendix J leak test requirements as stated in the introduction to 10 CFR 50, Appendix J is to " assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of containment, and systems and components penetrating primary containment."

A revision to 10 CFR 50, Appendix J was issued on September 26, 1995 in Federal Register Volume 60, No. 186. The revision establishes Option B - Performance-Based i Requirements, for conducting integrated leak rate tests and local leak rate tests. Regulatory Guide 1.163,

" Performance-Based Containment Leak-Test Program," dated September 1995, was issued and endorses, with exceptions, NEI 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Revision 0.

l The NRC Staff issued the revised 10 CFR 50, Appendix J as

! part of the initiative to eliminate requirements that are marginal to safety. This effort is discussed in SECY 036, " Staff Plans for Revising 10 CFR 50, Appendix J, Containment Leakage Testing, and for Handling Exemption Requests," dated February 17, 1994; and SECY-94-090,

" Institutionalization of Continuing Program for Regulatory Improvement," dated March 31, 1994.

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Attach;snt 3 Page 2 of 4 l i

Appendix J, as revised by Option B, establishes new l performance-based requirements and criteria for periodic leak rate testing. With Option B, the schedule requirements for integrated leak rate tests and local leak rate tests j will be based upon the previous test results. NEI 94-01 was I developed to provide guidance to implement Option B snd the justification for extended test intervals is based on performance history and risk insightc. Regulatory Guide 1.163, which endorses NEI 94-01, Revision 0, with ;

exceptions, provides specific guidance on developing a !

performance-based leakage test program, acceptable leakage I rate test methods, procedures, and analyses that may be used l to implement the requirements and criteria of Option B. The I Callaway Containment Leakage Rate Testing Program would 1 implement performance-based testing as allowed by Option B of 10 CFR 50, Appendix J.

Justification The proposed change to TS 3/4.6.1.1, 3/4.6.1.3 and 6.8.4g ,

would revise or support the implementation of performance- j based leakage rate testing, instead of paraphrasing Appendix J as is done in the present TS. There are no changes to'the test type, test methodologies or test acceptance criteria, only the required frequency of tests would be affected.

These changes will allow Union Electric to implement the y recent revision to 10 CFR 50, Appendix J. l Implementation of the Containment Integrated Leakage Rate Program would allow the integrated leak rate test presently scheduled for Refuel 8 to be rescheduled, since the criteria established by Appendix J, Option B, which requires only one integrated leak rate test in 10 years is presently satisfied by past integrated leak rate test results. Add >.tionally, Type B and C tests presently scheduled for Refuel 8 could also be evaluated for rescheduling, since they may also meet the criteria for test frequency extension. Adoption of the new performance-based leakage rate testing program will result in significant dollar and radiation exposure savings since unnecessary testing can be eliminated.

Additional Information License Amendment No. 98 and an exemption from the requirements of 10 CFR 50, Appendix J, Section III.D.1.(a) were granted for Callaway Plant on April 5, 1995 and April 4, 1995, respectively. The license amendment and exemption provided relief from the requirements to perform the overall integrated containment leakage rate test at intervals of 40 plus or minus 10 months. The approval of the license

Attachnznt 3 Page 3 of 4 amendment and exemption allowed the schedule for the-third Type A test to be extended to Refuel 8. However, with the adoption of 10 CFR 50, Appendix J, Option B, the overall integrated containment leakage rate test scheduled for Refuel 8 will be rescheduled, based upon past performance history of Type A tests performed at Callaway Plant, using the criteria provided in~NEI 94-01, Revision 0.

Evaluation This license amendment requests a revision to Technical Specification (TS) 3/4.6.1.1, " Containment Integrity," and 3/4.6.1.3, " Containment Air Locks" to implement performance-based leakage rate testing as permitted by 10 CFR 50, Appendix J. TS 6.8.4 would be revised by the addition of the leakage rate testing program. These changes srpport the implementation of performance-based testing allowed by Appendix J, Option B for Type A, B and C containment leak rate testing.

The proposed changes to the TS do not involve an unreviewed safety question because operation of Callaway Plant with this change would not:

1. Increase the probability of occurrence or the l consequences of an accident or malfunction of equipment ;

important to safety previously evaluated in the Safety Analysis Report. ;

l The proposed changes to TS 3/4.6.1.1 and 3/4.6.1.3 and l the program addition to TS 6.8.4g have no effect on plant operation. The proposed changes only provide mechanisms within TS for implementing a performance-based methodology for determining the frequency of leak rate testing, as allowed by the NRC. The test type, method, and acceptance criteria will not be changed.

Containment leakage will continue to be maintained within the required limits. Based on industry and NRC evaluations performed in support of developing Option B, these changes potentially result in a minor increase in the consequences of an accident previously evaluated due to the increased testing intervals. However, the proposed changes do not result in an increase in the core damage frequency since the containment system is used for mitigation purposes only.

Directly referencing the Containment Leakage Rate l Testing Program for Containment ILRT and LLRT requirements does not involve any modification to plant equipment or affect tho operation or design basis of 1

o Attachn nt 3 Page 4 of 4 the containment. Leakage rate testing is not a precursor to or an initiating event for any accident.

Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility for an accident or malfunction of equipment of a different type than any previously evaluated in the Safety Analysis Report.

The proposed changes only allow for implementation of 10 CFR 50, Appendix J, Option B and do not involve any modifications to any plant equipment or affect the operation or design basis of the containment. The proposed changes do not affect the response of the '

containment during a design basis accident.

3. Reduce the margin of safety as defined in the basis for any technical specification.

The proposed changes do not affect or change a safety limit, any limiting condition for operation or affect plant operations. The changes only implement the Appendix J, Option B test frequencies that have been determined by NRC not to involve a safety concern. The testing methods, acceptance criteria and bases are not changed and still provide assurance that the containment will provide its intended function.

Conclusion Given tha above discussions as well as those presented in l the Significant Hazards Consideration, the proposed change i does not adversely affect or endanger the health or safety I

! of the general public or involve an unreviewed safety question.

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e ATTACHMENT 4 SIGNIFICANT HAZARDS EVALUATION l

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SIGNIFICANT HAZARDS EVALUATION This license amendment requests a revision to Technical Specification (TS) 3/4.6.1.1, " Containment Integrity," and 3/4.6.1.3, " Containment Air Locks" to implement performance based leakage rate testing as permitted by 10 CFR 50, Appendix J.

TS 6.8.4 would be revised by the addition of the leakaga rate testing program description. These changes support by allowed theAppend implementation of performance based testing

3. J, Option B for Type A, B and C containment leak rate testing.

This proposed change is consistent with the revision to 10 CFR 50, Appendix J as noticed in 60 FR 49495 dated September 26, 1995.

A similar request to partially implement Option B for Type B and C testing has been r caitted by Georgia Power Company for Vogtle Electric Generating Plant.

Background

The purpose of Appendix J leak test requirements as stated in the introduction to 10 CFR 50, Appendix J is to " assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that p2oper maintenance and repairs are made during the service life of containment, and systems and components penetrating primary containment."

A revision to 10 CFR 50, Appendix J was issued on September l

26, 1995 in Federal Register Volume 60, No. 186. The revision establishes Option B - Performance-Based i

Requirements, for conducting integrated leak rate tests and local leak rate tests. Regulatory Guide 1.163,

" Performance-Based Containment Leak-Test Program," dated September 1995, was issued and endorses, with exceptions, NEI 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Revision 0.

' The NRC Staff issued the revised 10CFR 50, Appendix J as part of the initiative to eliminate requi'rements that.are marginal to safety. This effort is discussed in SECY 036, "Staf f Plans for Revising 10 CFR 50, Appendix J, Containment Leakage Testing, and for Handling Exemption Requests," dated February 17, 1994; and SECY-94-090,

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Attachment 4 i' Page 2 of 4

" Institutionalization of Continuing Program for Regulatory Improvement," dated March 31, 1994.

Appendix J, as revised by Option B, establishes new performance-based leak rate testing. requirements and criteria for periodic With Option B, the schedule requirements for integrated leak rate tests and local leak rate tests will be based upon the previous test results. 'NEI 94-01 was developed to provide guidance to implement Option B and the justification for extended test intervals is based on performance history and risk insights. Regulatory Guide 1.163, which endorses NEI 94-01, Revision 0, with exceptions, provides specific guidance on developing a performance-based leakage test program, acceptable leakage rate test methods, procedures, and analyses that may be used to implement the requirements and criteria of Option B. The Callaway Containment Leakage Rate Testing Program would implement of 10 CFR 50, performance-based Appendix J. testing as allowed by Option B Justification The proposed change to TS 3/4.6.1.1, 3/4.6.1.3 and 6.8.4g would. revise or support the. implementation of performance-based leakage rate testing, J as is done in the present TS.instead of paraphrasing Appendix test type, There are no changes to the test methodologies or test acceptance criteria, only the required frequency of tests would be affected.

These changes will allow Union Electric to implement the recent revision to 10 CFR 50, Appendix J.

Implementation of the Containment Integrated Leakage Rate Program would allow the integrated leak rate test presently scheduled'for Refuel 8 to be rescheduled, since the criteria established by Appendix J, Option B, which requires only one )

integrated leak rate test in 10 years is presently satisfied by past integrated leak rate test results. Additionally, Type B and C tests presently scheduled for Refuel 8 could also be evaluated for rescheduling, since they may also meet the criteria for test frequency extension. Adoption of the

-new performance-based leakage rate testing program will result in significant dollar and radiation exposure savings since unnecessary testing can be eliminated.

Additional Information License Amendment No. 98 and an exemption from the requirements of 10 CFR 50, Appendix J, Section III .D. l . (a) were granted for Callaway Plant on April 5, 1995 and April

Attachment 4 Page 3 of 4 4, 1995, respectively. The license amendment and exemption provided relief from the' requirements to perform the overall integrated containment leakage rate test at intervals of 40 plus or minus 10 months. The approval of the license amendment and exemption allowed the schedule for the third Type A test to be extended to Refuel 8. However, with the adoption of 10 CFR 50, Appendix J, Option B, the overall i integrated containment leakage rate test scheduled for Refuel 8 will be rescheduled, based upon past performance history of Type A tests performed at Callaway Plant, using the criteria provided in NEI 94-01, Revision 0. ,

Evaluation This_ license amendmeni requests a revision to Technical Specification (TS) 3/4.6.1.1, " Containment Integrity," and 3/4.6.1.3, " Containment Air Locks" to implemant performance-based leakage rate testing as permitted by 10 CFR 50, Appendix J.

TS 6.8.4 would be revised by the addition of the leakage rate testing program. These changes support the i implementation of performance-based testing allowed by Appendix J, Option B for Type A, rate testing. B and C containment leak The proposed changes to the TS do not involve a significant hazards consideration because operation of Callaway Plant with this change would not:

1.

Involve a significant increase in the probability of occurrence or the consequences of an accident or-malfunction of equipment important to safety previously ,

l evaluated in the Safety Analysis Report. i I

i l The proposed changes to TS 3/4.6.1.1 and 3/4.6.1.3 and i

! the program addition to TS 6.8.4g have no affect on l plant operation. The proposed changes only provide mechanisms within TS for implementing a performance-based methodology for determining the frequency of leak rate testing, as allowed by the NRC. The test type, i

method, and acceptance criteria will not be changed.

Containment leakage will continue to be maintai.,ed t

within the required limits. Based on industry and NRC evaluations performed in support of developing Option B, +

in

'se changes potentially result'in a minor increase r.e consequences of an accident previously evaluated i

due oo the increased testing intervals. However, the j

' proposed changes do not result in an increase in the ;

core damage frequency since the containment system is used for mitigation purposes only.

Attachment 4 Page 4 of 4 Directly referencing the Containment Leakage Rate Testing Program for Containment ILRT and LLRT l requirements does not involve any modification to plant l equipment or affect the operation or design basis of l

the containment. Leakage rate testing is not a precursor to or an initiating event for any accident.

Therefore, these changes do not involve a significant l increase in the probability or consequences of an l accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any previously evaluated in the safety Analysis Report.

The proposed changes only allow for implementation of 10 CFR 50, Appendix J, Option B and do not involve any modifications to any plant equipment or affect the operation or design basis of the containment. The proposed changes do not affect the response of the containment during a design basis accident.

3. Involve ~a significant reduction in a margin of safety.

The proposed changes do not affect or change a safety i

limit, any limiting condition for operation or affect l

plant operations. The changes only implement the Appendix J, Option B test frequencies that have been determined by NRC not to involve a safety concern. The testing methods, acceptance criteria and bases are not

' changed and still provide assurance that the containment will provide its intended function.

Conclusion Given the above discussions as well as those presented in the Safety Evaluation, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant hazards consideration.

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ATTACHMENT 5 ENVIRONMENTAL CONSIDERATION l

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Attachment 5 Page 1 of 1 !

l ENVIRONMENTAL CONSIDERATION j This license amendment requests a revision to Technical Specification (TS) 3/4.6.1.1, " Containment Integrity," and :

3/4.6.1.3, " Containment Air Locks" to implement performance !

based leakage rate testing as permitted-by 10 CFR 50, Appendix J. TS 6.8.4 would be revised by the addition of the l

leakage rate testing program description. These changes !

support the implementation of performance based testing allowed by Appendix J, Option B for Type A, B and C containment leak rate testing. i

{

The proposed amendment involves changes with respect to the l use of facility components located within the restricted !

{

area, as defined in 10 CFR 20, and changes surveillance requirements. ]

Union Electric has determined that the '

proposed amendment does not involve:

(1) A significant hazard consideration, as discussed in Attachment 4 of this amendment application; (2) A significant change in the' types or significant increase in the amounts of any effluents that may be released offsite; (3) A significant increase in individual or cumulative occupational radiation exposure. ,

l Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR l 51.22 (c) (9) . Pursuant to 10 CFR 51.22 (b), no environmental !

l' impact statement or enviromental assessment need be prepared in connection with the issuance of this amendment.

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ML20097F899

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