ML20116L632

Proposed Tech Specs Re Primary Containment/Drywell Hydrogen Mixing Sys & Drywell Isolation Valves

ML20116L632
Person / Time
Site:	River Bend
Issue date:	08/01/1996
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20116L630	List: ML20116L632 RBG-42913, Application for Amend to License NPF-47,revising Primary Containment/Drywell Hydrogen Mixing Sys & Drywell Isolation Valves
References
NUDOCS 9608190130
Download: ML20116L632 (17)

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9608190130 960001 PDR ADOCK 05000458 P PDR

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l Primary Containment /Drywell Hydrogen Mixing System i , . _

3.6.3.3 ACTIONS (continued) l l

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. CONDITION REQUIRED ACTION COMPLETION TIME i

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i C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

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l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY k SR 3.6.3.3.1 Operate each primary containment /drywell 72 cy:

' hydrogen mixing subsystem for 4 a 15 minutes.

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! l SR 3.6.3.3.2 Verify each primary containment /drywell 18 months hydrogen mixing subsystem flow rate is a 600 cfm.

l Biery COLV SHbfT00wk # no1 penumd wm tu gav,eu, o da 9 RIVER BEND 3.6-45 Amendment No. 81

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11 i Drywell Isolation Valves j

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3.6.5.3

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i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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! A. (continued) A.2 --------NOTE---------

Isolation devices in high radiation areas

- may be verified by use of administrative means.

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Verify the affected Prior to penetration flow path entering MODE 2

{ is isolated. or 3 from .

i MODE 4, if not j performed within 4 the previous 92 days i

B. One or more B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4

penetration flow paths penetration flow path l with two drywell by use of at least 4 isolation valves one closed and inoperable. de-activated automatic valve, closed manual valve, j blind flange, or

check valve with flow I through the valve

! secured.

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t?.I 1 Required Action and .C,+ Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion p, Time not met. A!E 3

-Cet Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> l P.2 l l

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J RIVER BEND 3.6-68 Amendment No. 81

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INSERT A l

! C. One or more Hydrogen C.1 Isolate the affected penetration Immediately '

Mixing penetration flow flow path by use of at least one paths not within the closed and de-activated automatic l l limitations specified in SR valve, blind flange, or check valve l 3.6.5.3.6 with flow through the valve I secured. ,

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1 Drywell Isolation Valv::s 3.6.5.3 SURVEILLANCEREhUIREMENTS SURVEILLANCE FREQUENCY 3.6.5.3.1 Verify each 24 inch drywell purge 31 days SR isolation valve is sealed closed.

SR 3.6.5.3.2 ----------.------NOTE--------------------

Not required to be met when the primary containment /drywell hydrogen mixing inlet or outlet.valvas,are open,for pressure l contro A 'or air quality for pp sonnel e ry. Al s erati n requi to be t durin p urveil nces or pacial te ing on he hydr. n mixin system that ' requi th

<va Wes to be 6 pen.

Verify each primary containment /drywell 31 days ,

I hydrogen mixing isolation valve is t closed.

SR 3.6.5.3.3 ------------------NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for drywell isolation valves that are open under administrative controls.

Verify each drywell isolation manual Prior to valve and blind flange that is required entering MODE 2 to be closed during accident conditions or 3 from MODE 4, if not is closed. performed in the previous 92 days (continued)

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3.6-69 Amendment No. 81 RIVER SEE

I Drywell Isolation Valves 'I '

• 'l.6.5.3 S'URVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.5.3.4 Verify the isolation time of each power In accordance operated and each automatic drywell with the isolation valve is within limits. Inservice Testing Program l

i SR 3.6.5.3.5 Verify each automatic drywell isolation 18 months i valve actuates to the isolation position l

, on an actual or simulated isolation signal.

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• WS JJenetrat i ons a tt of tn To b t' 4Fhourg (Er NT day 9 h1 his]CS 1.<,, A R an d 6 TC h e 4rr f e r J W days Ili NCkC 7 -

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4 RIVER BEND 3.6-70 Amendment No. 81 l ..

Prirary Containment /Drywell Hydrog:n Mixing System '

, 8 3.6.3.3

. BASES ACTIONS B.1 and B.2 (continued)

With two primary containment /drywell hydrogen mixing subsystems inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The alternate hydrogen control capabilities are provided by one division of the hydrogen igniters. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. The verification may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control system. It does not mean to

.- perform the surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control system. If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two primary containment /drywell hydrogen mixing subsystems inoperable for up to 7, days. Seven days is a reasonable time to allow two primary containment /drywell hydrogen mixing subsystems to be inoperable because the hydrogen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen in amounts capable of exceeding the flammability limit.

C.d If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed l Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on j operating experience, to reach MODE 3 from full power 1 conditions in an orderly manner and without challenging  ;

plant systems. l l

SURVEILLANCE SR 3.6.3.3.1 REQUIREMENTS Operating each primary containment /drywell hydrogen mixing l .

subsystem from the control room for a 15 minutes ensures  ;

that each subsystem is OPERABLE and that all associated l controls are functioning properly. It also ensures that l blockage, fan failure, or excessive vibration can be NMN- J nt w sM c (continued)

RIVER BEND B 3.6-81 Revision No. 1

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INSERT A The frequency is restricted to COLD SHUTDOWN conditions to funit the opening of the hydrogen mixing inlet and outlai alves e during MODES 1,2, and 3, because these valves have never been demonstrated capable of closing during accident conditions in the drywell (Reference 3). The 92 day frequency is consistent with operating experience, the known ,

reliability of the fan and controls, and the two redundant subsystems available.

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Primary Containoext/Orywell Hydrogen Mixing System h B 3.6.3.3  ;

BASES l SURVEILLANCE SR 3.6.3.3.1 (continued)

REQUIREMENTS f

Progr requenciesv operating experience, he known i

r ility of th(fan and con,trols, and a two re dant ubsystems avsTTable. / -

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SR 3.6.3.3.2 l

Verifying that each primary containment /drywell hydrogen l mixing subsystem flow rate is a 600 cfm ensures that each subsystem is capable of maintaining drywell hydrogen concentrations below the flammability limit. The 18 month Frequency is based on the need to perform this Surveillance

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under the conditions that apply during a plant outage when the drywell boundary is not required. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1. Regulatory Guide 1.7, Revision 2.

2. USAR, Section 6.2.5.

3 GR 46 - 076 7, l

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l RIVER BEND B 3.6-82 Revision No. O

l Orywell Isolation Valves B 3.6.5.3

' BASES ACTIONS. B.d (continued)

With one or more penetration flow paths with two drywell l

isolation valves inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, a blind i

flange, and a check valve with flow through the valve l secured. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is acceptable, since if l the drywell design bypass leakage AM of 1.0 ft were 8

, exceeded, ACTIONS Note 4 will ensure appropriate conservative actions are implemented. The Completion Time is reasonable, considering the time required to isolate the penetration, and the probability of a DBA, which requires i

the drywell isolation valves to close, occurring during this )

short time is very low.

JWFRT C- y .

C .1 =d C. 2- P, / an d 8, 2 _

If any Required Action and associated Completion Time cannot be met, the plant must be placed in a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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.

SURVEILLANCE SR 3.6.5.3.1 REQUIREMENTS Each 24 inch drywell purge isolation valve is required to be verified sealed closed at 31 day intervals. This Surveillance is required since the drywell purge isolation valves are not qualit<ied to close under accident conditions.

This SR is designed to ensure that a gross breach of drywell  !

is not caused by an inadvertent or spurious drywell purge l isolation valve opening. Detailed analysis of these 24 inch l drywell purge valves failed to conclusively demonstrate l their ability to close during a LOCA in time to support i drywell OPERABILITY. Therefore, these valves are required to be in sealed closed position during M00ES 1, 2, and 3.

These 24 inch drywell purge valves that are sealed closed must have motive power to the valve operator removed. This (continued) i 1

RIVER BEND B 3.6-133 Revision No. 0 1

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1 INSsRT C C_t With one or more hydrogen mixing penetration flow path not within the limitations specified in SR 3.6.5.3.6, the penetration flow paths for hydrogen mixing must be isolated immediately. Since the hydrogen mixing valves have never been demonstrated capable of closing under accident conditions in the drywell, closing the valves ensures drywell integrity should the limitations of SR 3.6.5.3.6 be exceeded.

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Orywell Isolation Valves 7

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SURVEILLANCE SR 3.6.5.3.1 (continued) l REQUIREMENTS can be accomplished by de-energizing the source of electric  ;

power or removing the air supply to the valve operator. In  ;

this application, the term " sealed" has no connotation of leakage within limits. The Frequency is based on purge valve use during unit operations.

SR 3.6.5.3.2

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i This SR ensures that the primary containment /drywell

! hydrogen mixing isolation valves are closed as required or, l i if open, open for an allowable reason for limited periods of I time. This SR has been modified by a Note indicating the SR l is not required to be met when the primary containment /drywell hydrogen mixi inlet or outlet valves l or air ality atto en for orsssure control.( A l l

cons eratto V for pers One ont , or Sur illance or sp ial tesAlng of th mixina e stge_1b4 reauire/

at valveditb_e open hydro the 3- (day Frequency is consistent

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with the valve requ rements discussed under SR 3.6.5.3.1.

1 j SR 3.6.5.3.3 i  !

This SR requires verification that each drywell isolation manual valve and blind flange that is required to be closed j during accident conditions is closed. The SR helps to ensure that drywell bypass leakage is maintained to a minimum. Due to the location of these devices, the Frequency specified as " prior to entering MODE 2 or 3 from j M0DE 4, if not performed in the previous 92 days," is i

appropriate because of the inaccessibility of the devices j and because these devices are operated under administrative controls and the probability of their misalignment is low.

Two Notes are added to this SR. The first Note allows j valves and blind flanges located in high radiation areas to j be verified by use of administrative controls. Allowing j verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1, 2, and 3. Therefore, the probability of misalignment of these devices, once they have j been verified to be in their proper msition, is low. A i

second Note is included to clarify ttat the drywell j isolation valves that are open'under administrative controls ,

l are not required to meet the SR during the time that the j devices are open.

j (continuedl i

RIVER BEle 8 3.6-134 Revision No. 0 l

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Drywell Isolation Valves I

, 8 3.6.5.3-BASES-SURVEILLANCE SR 3.6.5.3.4 REQUIREMENTS (continued) Verifying that the isolation time of each power operated and each automatic drywell isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time te.st ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR Are in accordance j with the Inservice Testing Program.

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j SR 3.6.5.3.5 j "

Verifying that each automatic drywell isolation valve closes l on a drywell isolation signal is required to prevent bypass j leakage from the drywell following a D8A. This SR ensures

each automatic drywell isolation valve will actuate to its

! isolation position on a drywell isolation signal. The LOGIC i SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.6 overlaps this SR to i provide complete testing of the safety function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the i Surveillance were performed with the reactor at power, since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components. Operating experience has shown these components usually pass this Surveillance when performed at the 3

i ggp e 18' month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1. USAR, Section 6.2.4.

2. USAR, Table 6.2-40.

3. CR 96 -6 7c 7 RIVER BEND 8 3.6-135 Revision No. 0

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= SR 3.6.5.3.6 l This SR ensures that the hydrogen mixing valves remain closed during Modes 1,2, and 3,  !

or, if open, are only open for a limited period of time over a 365 day cycle. Since the i hydrogen mixing isolation valves have never been demonstrated capable of closing under -

accident conditions in the drywell, this SR applies rcstrictions to the opening of these -

valves (Reference 3). The frequency of this SR is consistent with the frequency of SR 3.6.3.2 and allows the administrative tracking of the hours open to be performed  !

concurrently with the isolation valve closure verification. ,

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i NITACHMENT 4 Old Technical Specification Pages ;

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) CONTAINMENT SYSTEMS i

j . PRIMARY CONTAINMENT /ORYWELL HYOROGEN MIXING SYSTEM LIMITING CONDITION FOR OPERATION j 4

l 3.6.6.2 Two primary containment /drywell hydrogen mixing systems shall be

OPERA 8LE and the inlet and outlet valves shall be closed, except one inlet or outlet line may be opened for controlling drywell pressure with the following' j time Ifmits:

i a. In OPERATIONAL CONDITION 3, not to exceed 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />" per 365 days, and

b. In OPERATIONAL CONDITION 1 or 2, not to exceed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

• per 365 days.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

! a. With one hydrogen mixing system inlet or outlet line open during i OPERATIONAL CONDITIONS 1 and 2 for more than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />" per 365 days, j immediately close the hydrogen mixing valves or be in at least HOT j SHUTOOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

1 b. With one hydrogen mixing system inlet or outlet line open during - -

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. OPERATIONAL CONDITION 3 for more than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />

• per 365 days, l immediately close the hydrogen mixing valves or be in at least COLD i SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. With one primary containment /drywell hydrogen mixing system inoperable, restore the inoperable system to OPERABLE status within 30 days or be l in at least HOT SHUTOOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

i "When personnel access is necessary and ammonia levels are > 5 ppe, all mixing lines may be open with the fans operating. The time during which the mixing system is in operation for ammonia purge does not contribute to the cumulative total time, provided THERMAL POWER does not exceed 5% of RATED THERMAL POWER.

4 RIVER BENO - UNIT 1 3/4 6-62

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l CONTAINMENT SYSTEMS

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SURVEILLANCE REQUIREMENTS

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4.6.6.2 Each primary containment /drywell hydrogen mixing systes shall be demonstrated OPERA 8LE:

a. At least once per 7 days, by determining the cumulative time that:

1. The hydrogen mixing system inlet or outlet line has been open during OPERATIONAL CONDITIONS 1 and 2 during the past 365 days, and

2. The hydrogen mixing system inlet or outlet line has been open during OPERATIONAL CONDITION 3 during the past 365 days.

b. During each COLD SHUTDOWN, if not performed within the previous 92 days, by:

1. Starting the system from the control room, and

2. Verifying that the system operates for at least 15 minutes. -

c. At least once per 18 months by verifying a system flow rate of at least 600 cfm. -

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