ML20105D337

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Proposed TS Changes to Bases for TS 3/4.6.1.2 Re Limitations on Containment Leakage Rates & Surveillance Testing for Measuring Leakage Rates,Per App J to 10CFR50
ML20105D337
Person / Time
Site: Callaway Ameren icon.png
Issue date: 09/16/1992
From:
UNION ELECTRIC CO.
To:
Shared Package
ML20105D333 List:
References
ULNRC-2699, NUDOCS 9209250044
Download: ML20105D337 (4)


Text

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e Attachment to U L!1RC-2 099 l'ROPOSED TI:Cill11 CAL SPECIFICATIO!1 CilA11GES Ilanen 3/4.6.1.2 1

9209250044 o?O916 PDR ADOCK 05000403 PDR p

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3/4.6 CONTA!NMENT SYSTEMS

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'\\ g BASES 3/4.6.1 PRIMARY CONTAINNENT i

_3 /4. 6.1.1 CONTAINHENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atJnosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the dose guideline valu s 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 accident analyses at the peak accident pressure. P,.

As an added conservatism, the

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measured overall integrated leakage rate is further limited to less than or equal to 0.75 L,. during performar.ca of the periodic test to account for possible,degradaygn of the containment leakage' barriers between leakage tests.

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[ y The surveillance t sting for measuring leakage rates.are consistent with

' j the requirements of Ap'pe dix J of 10 CFR Part 50.

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3/4.6.1.3 CONTAINMENT IR LOCKS The limitatit.es-on closure and leak rate for the containment air locks

((are required to meet the restrictions on CONTAINHENT INTEGRITY and co le k rate. 75urve111ance testing of the air lock seals provides assurance that th 'overall air lock leakage will not becore excessive due to seal damage during the intervals between air lock leaksge tests.

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- t 1HSERT A l

The following exemptions have boon granted to the requirements of Appendix J of 10 CFR part 50 1.

Section III.A.1(a) - an exemption to the requiro-mont to stop the Typo A test if excessive leakage-is datormined.

This exemption allows the satis-factory completion of the Typo A test if tho i

leakage can be isolated and_ appropriately. factored into the results.

(NRC Lotter, dated October.22, 1991) 2.

Section III.A b(b) - an exemption for the accep-tanco critoria, in lieu of the present singlo critorion of the total measured-containment leakage rate being less than 0.75 of the maximum allowablo:

leaktgo rato, L,

the "as found" allowablo lonkage a

rate will be L and the "as left" allowable leakago ratu will bo 10ss than 0.75 L.

(NRC Lottor, dated a

October 22, 1991) 3.

Section III.D.1(a) - an exemption that removes tho requirement that the third test of each set of-three Type A test be conducted when the plant _is shutdown for the 10-your. plant incorvice inspection.

(NRC Lottor, datod' October 22, 1991)

Exemptions 1 and 2 allow tho'continusnce of1a Type A-test when excessivo leakage-is found provided that significant leaks are identified and isolated.

The "as; found" acceptanco critoria of L.is dotormined from~the J

measured leakago rato during th8 performanco of a, Type.A test.plus any leakagoLimprovements prior to.the-test.

Loakago improvements are defined as tho' difference betwoon

.the pro-LLRT and post-LLRT dono on-containment penotrations prior to.the start of tho. Typo A test. _ Th o " a s 3 c f t" --

acceptance critoria of 0.75 L@ the test.

is based on the measured leakage-rate-determined durin It rhould be noted I

that additional-adjustments _for non-standard _ lineup and changes.in' containment'volumo are added_to tho_ measured leakago rate'for.both "as_found" and "as loft"l l

dotorminations.

This adjusted "as found" leakago rate is to-l be used in_ determining'the scheduling of the periodic Type A test in accordance with Section III.A.6-of Appendix J.

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e The acceptability of the modified Type A test can be determined by cniculating the adjusted "as left" containment overall integrated leakage rate and comparing it to the acceptance criteria of 0.75 L.

The adjusted "as left" Type A leakage rate is determined 6y adding the local leakage rates measured, after any repairs and/or adjustments to those previously isolated leakage paths, to the leakage rate determined in the modified Type A test.

The only differences between this approach and Appendix J requirements are thatt (1) the potentially excessive leakage paths will be repaired and/or adjusted after the Type A test is completed; and (2) the Type A tout leakage rate in partially determined by calculations rather than by direct.noasurement.

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