ML20136H284
| ML20136H284 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/14/1997 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20136H271 | List: |
| References | |
| NUDOCS 9703190106 | |
| Download: ML20136H284 (8) | |
Text
_. _. _. _ _ _ - - _. _.. _ _ _ _ _ _ _... _ _.... _ -. _...
i l
l i
i i
l I
1 l
NPF-38-188 i
l ATTACHMENT A-Revised pages of NPF-38-188 I
l l
I l
t 4
9703190106 970314 PDR ADOCK 05000382 P
PDR i
\\
CO'NTAINMENT SYSTEMS CONTAINMENT VENTILATION SYSTEM i
LIMITING CONDITION FOR OPERATION l
3.6.1.7 Each containment purge supply and exhaust isolation valve (CAP 103, CAP 104, CAP 203, and CAP 204) shall be OPERABLE and may be open at no greater than the 52' open position allowed by the mechanical stop for less than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days.
APPLICABILITY: MODES 1,2,3, and 4.
ACTION:
a With a containment purge supply and/or exhaust isolation valve (s) open for greater than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days at any open position, close the open valve (s) or isolate the penetration (s) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, othenuise be in at least HOT STANDBY within the next 6
)
hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b. With a containment purge supply and/or exhaust isolation valve (s) having a measured leakage rate exceeding the limits of Surveillance Requirement 4.6.1.7.2, restore the I
inoperable valve (s) to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, otherwise 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 SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REOUIREMENTS 4.6.1.7.1 The cumulative time that the purge supply or exhaust isolation valves are open during the past 365 days shall be determined at least once per 7 days.
4.6.1.7.2 At least once per 3 months each containment purge supply and exhaust isolation valve with resilient material seals shall be demonstrated OPERABLE in accordance with the I
Containment Leakage Rate Testing Program.
4.6.1.7.3 Each containment purge supply and exhaust isolation valve shall be demonstrated OPERABLE during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying that the mechanical stops limit the valve opening to a position < 52' open.
l WATERFORD - UNIT 3 3/4 6-15
l l
i
=
3/4 6 CONTAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENT 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 l
assumed in the safety analyses. This restriction, in conjunction with the leakage rate limitation, will l
limit the SITE BOUNDARY radiation doses to within the limits of 10 CFR Part 100 during accident i
conditions.
l l
3/4.6.1.2 CONTAINMENT LEAKAGE 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, Pa.
As an added conservatism, the measured overall integrated leakage rate is further limited to < 0.75 La during the performance of periodic Type A tests to account for possible degradation of the containment leakage barriers between leakage tests. Also, the summation of penetration leakages l
measured during Type B and C testing is limited to 0.6 La. At all other times between required leakage rate tests, overall containment leakage is limited to La. The maximum allowable containment l
leakage rate, La, is 0.5 % 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 the design basis accident pressure, Pa, of 44 psig.
The surveillance requirements for measuring leakage rates are consistant with the requirements of j
l 10CFR50, Appendix J, Option B, and leakage rate testing is performed in accordance with the guidelines contained in Regulatory Guide 1.163, ' Performance-Based Containment Leak-Test i
Program'. Leakage rate testing is conducted periodically as specified in the Containment Leakage Rate Testing Program.
1 The periodic performance of Type A, B and C tests verifies that the containment leakage rate does not exceed the levels assumed in the safety analyses.
Secondary containment bypass leakage paths previously identified in Table 3.6-1 are now identified in the Technical Requirements Manual.
3/4.6.1.3 CONTAINMENT AIR LOCKS The 1611tations on closure and leak rate for the containment air locks are required to meet the restrictionr, on CONTAINMENT INTEGRITY and containment leak rate. Surveillance testing of the l
air lock Feals provides assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between air lock leakage tests.
i l
l i
k WATERFORD - UNIT 3 8 3/4 6-1 AMENDMENT NO. 440
.~
CONTAINMENT LEAKAGE RATE TESTING PROGRAM (Continued)
Leakage rate acceptance criteria are:
a.
Containment leakage rate acceptance criteria is s 1.0 La. During the first unit startup following each test performed in accordance with this program, ther leakage rate 4
acceptance criteria are s 0.60 La for the Type B and Type C tests and s 0.75 La for Type A tests, b.
Air lock acceptance criteria are:
1.
Overall air lock leakage rate is s 0.05 La when ested at 2 Pa.
2.
Leakage rate for each door is s 0.01 La when pressurized to 210 psig.
c.
Combined bypass leakage rate acceptance criteria is s 0.06 La when tested at 2 Pa.
d.
Containment purge valves with resilient seals acceptance criteria is s 0.06 La when tested at 2 Pa.
The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.
The provisions of Specification 4.0.3 are applicable to the Containment Leakage Rate Testing Program.
WATERFORD - UNIT 3 6-25
I l
I 1
i i
NPF-38-188 ATTACHMENT B j
Differences Between The Waterford 3 Submittal and the NRC Model i
l 4
l
DETAILS OF DIFFERENCES l
W-3 TS 3.6.1.1, Containment Integrity, uses as ACTIONS its current ACTIONS to restore containment integrity within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The Model uses 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,12 hours, and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This difference is due to the Model being written to the Improved TS and Waterford using the Standard TS. This is not a deviation from Option B, but a difference between the Standard TS and the Model TS. This is acceptable as W-3's ACTION is more conservative than the MODEL.
l Surveillance Requirement 4.6.1.1.a and 4.6.1.1.b are retained in the W-3 l
Requirements as these are requirements outside of Option B and should be retained l
in the specification. The annotation for 4.6.1.1.a is likewise applicable to the current t
W-3 format. While the proposed format is somewhat different from the Model,' it preserves the structure of the current TS and is not inconsistent with RG 1.163. It is, therefore, acceptable.
The action statement for current TS 3.6.1.2, Containment Leakage, requires that with l
containment leakage rates not within limits, restore the leakage rates to within the limits " prior to increasing the reactor coolant temperature above 200 F." W-3 desires to maintain this wording, since most leak rate tests are performed while shutdown.
l Model TS 3.6.1.1 requires returning containment to operable condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or placing the unit in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within 36 L
hours. While the model TSs correct a deficiency in the current TS, which does not l
recognize that containment leakage rates can be determined during plant operation l
(Modes 1 through 4), keeping the current TSs Action is still adequately restrictive.
This is because limiting condition for operation (LCO) 3.0.3 of the current TSs, which is entered when an action of a particular Specification cannot be entered because of j
circumstances in excess of those addressed in the Specification, would apply if leakage were determined to be exceeded during plant operations. LCO 3.0.3 requires initiating action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in hot shutdown in 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 shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
l Because the required actions in the W-3 TSs are more conservative than the model TSs, this deviation is acceptable.' The specific value for bypass leakage has been i
moved to the Administrative Controls section, consistent with other specific values l
listed for containment leakage and air lock leakage.
W-3 TS 3.6.1.3, Containment Air Locks (which is TS 3.6.1.2 in the Model), is essentially equivalent to the Model, with changes due to differences in format and ACTION times between the current W-3 TS and the Model. W-3 LCO 3.6.1.3.a is equivalent to Note 1 of the Model and also addresses normal entry and exit. W-3 LCO 3.6.1.3.b defines operability as including overall air lock leakage for consistency I
with the current Specification and is equivalent to the Model, which contains this as a Surveillance Requirement. ACTION a1 and a2 are equivalent to the Model with only m
l a format change to the current W-3 TS. ACTION a3 for a containment air lock door is more conservative than that in the Model by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Action a4 is retained
. consistent with License Amendment 99 (see SER dated September 20.1994).
l ACTION b is more conservative than the Model by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The Surveillance Requirements are the same as the Model with the exception of the sealleakage and
'j overall leakage being two separate requirements, as at W-3 they are separate l-requirements. The Model has the Note to evaluate leak rate testing against the l
criteria applicable to SR 3.6.1.1, whereas the W-3 proposal references this SR in l
' 3.6.1.1. Because the required actions and Surveillance Requirements in the W-3 L
. TSs are either equivalent or more conservative than the model TSs, these deviations are acceptable.
W-3 TS 4.6.1.6, which requires visual examination of the accessible interior and exterior surfaces of containment is being revised to reference the Containment Leakage Rate Testing Program and delete the Special Report, which is no longer l
required by Option B. Note that the reporting requirements of 10CFR50.72 and i
10CFR50.73 are still applicable. While the proposed format is somewhat different than the model TSs, it preserves the structure of the current TSs and is consistent with RG 1.163, therefore, the proposed change is acceptable.
W-3 TS 3.6.1.7 for the containment purge isolation valves is contained in the Model as part of 3.6.1.3. The differences between the W-3 proposal and the MODEL j
[
essentially involve special testing required by W-3's being licensed to perform limited L
purges at power. This accounts for W-3's requirements for verifying cumulative open time in SR 4.6.1.7.1 and mechanical stop position in the LCO and SR 4.6.1.7.3.
ACTION a is required for this capacity and therefore is being retained in the -
Specification. ACTION b is more conservative' than the Model in that the option of l
continuing to operate with excessive leakage by use of a deactivated valve has not been incorporated into the W-3 proposal. Additionally, the completion times for required actions in the W-3 proposal are more conservative by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The l
. required frequency of 3 months for SR 4.6.1.7.2 is being retained rather than adopting the frequency of 184 days or within 92 days of opening the valves as specified in the Model. Since the W-3 proposal maintains previously approved features, and either conforms to or is more conservative than the Model, the proposed change is acceptable.
The proposal for the Administrative Controls section of the W-3 TS was amended to add the limits for containment bypass leakage and containment purge valves with resilient seals. This deviation from the Model is acceptable as these limits are in the current W-3 TS, and are merely being moved to the Administrative Controls consistent with other limits in the current TS.
1The Bases for TS 3/4.6.1.2 were modified to explain the leakage acceptance critoria and change the plant procedure number referenced for bypass leakage to the
- Technical Requirements Manual. In addition, a reference to Option B of 10 CFR Part l
l
~. =. -....
... ~...... _ -.
I ',
5d, Appendix J, and Regulatory Guide 1.163 were added for clarity. The W-3 Bases contains significantly less information than the Model Bases and, therefore, less changes are required to the W-3 Bases.
l l
I' I
l L
l tI-i I
l i
i V
--