ML20141L011

Proposed Tech Specs Revising Section 5.5.12 to Exclude Measured Main Steam Isolation Valves Leakage from Total Type B & C Local Leak Rate Test Results

ML20141L011
Person / Time
Site:	Peach Bottom
Issue date:	05/23/1997
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20141L010	List: ML20141L008 ML20141L011
References
NUDOCS 9706020242
Download: ML20141L011 (10)

Text

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Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Safety Function Determination Procram (SFDP) (continued) 1

1. A required system redundant to system (s) supported by I the inoperable support system is also inoperable; or l

2. A required system redundant to system (s) in turn supported by the inoperable supported system is also inoperable; or i

1

3. A required system redundant to support system (s) for the supported systems (b.1) and (b.2) above is also inoperable.

l

c. The SFDP identifies where a loss of safety function exists.

If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.12 Primary Containment Leakaoe Rate Testino Pronram 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, "Performanc -8 sed Containment Leak-Test Program," dated September 199 A The peak calculated containment in ernal prcssure for the design basis loss of coolant accident, P., is 49.1 psig.

\

The maximum allowable primary containment leakage rate, L,, at P.,, L shall be 0.5Y,of primary containment air weight per day. q Leakage Rate acceptance criteria are:

L] '

I

a. Primary Containment leakage rate acceptance criterion is s '

1.0 L, . During the first unit startup following testing in accordance with this program, the leakage rate acceptance J <

criteria are s 0.60 L, for the Type B and Type C tests and 5 '

O.75 L, for Type A tests; (continued))

v v_ ~

~%M bas modtfied by the following excepton to NEl 94-01, Rev. O, " Industry Guideline for g

implementng Performance-Based Opton of 10 CFR Part 50, Appendtx J", Secton 10.2;

a. MSIV leakage is excluded from tne combined total of

[. 0.6 L, for the Type B and C tests.

PBAPS UNIT 2 Amendment No. 210 9706020242 970523 PDR ADOCK 05000277 P PDR

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l

, , . Programs and Manuals 5.5 5.5 Programs and' Manuals 5.5.12 Primary Containment leakaae Rate Testina Proaram (continued)

b. Air lock testing acceptance criteria are:

• \

1) Overall air lock leakage rate is s 9000 sec/ min when {

tested at 1 P,. '

The provisions of SR 3.0.2 do not apply to the test frequencies specifieg in the Primary Containment Leakage Rate Testing Program.

l The provisions of SR 3.0.3 are applicable to the Primary I Containment Leakage Rate Testing Program. . l i

t

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c. MStV leakage acceptance entena are as specified in SR 3.6.1.3.14. )

\ J i

i PBAPS UNIT 2 5.0-18 Amencment No. 210

. Pr1 .. .. Containment l

. B 3.6.1.1 i

. i .

BASES l

SURVEILLANCE SR 3.6.1.1.1 (cont'inued)  ;

REQUIREMENTS valve leakage (SR 3.6.1.3.14), does not necessarily result ,

in a failure of this SR. The impact of the failure to meet i these Sns must be evaluated against the Type A, B, and C acceptance criteria of the Primary Containment Leakage Rate Testina Program.) l ft ea ge rio to he 'rst artup i a te pe fo in a qu e lea ge tes is qui to e  !

.6 , or c ned yp 8 nd le age, an 0. L, )

. v al Ty e A lea ge A al ot r ti es b wee l e le kag ra e t ts, th acc ta ce c 'ters i i n n ver il pe le kag lim't s 1._ L At s l' 0 L, the of fsite dose consequences are bounced by the assumptions of the safety analysis. The Frequency is required by the Primary Containment Leakage Rate Testing.

Program. ,

I i

, SR 3.6.1.1.2 Maintaining the pressure suppression function of primary l containment requires limiting the leakage from the drywell to the suppression chamber. Thus, if an event were to occur that pressurized the drywell, the steam would be directed through the downcomers into the suppression pool. This SR is a leak test that confirms that the bypass area between the drywell and the suppression chamber is less than or  ;

equivalent to a one-inch diameter hole (Ref. 4). This  !

! ensures that the leakage paths that would bypass the suppression pool are within allowable limits.

The leakage test is performed every '24 months. The 24 month Frequency was developed considering that compolent failures that might have affected this test are identified by other primary centainment SRs. Two consecutive test failures, however, would indicate unexpected primary containment degradation; in this event, as the Note indicates, a test shall be performed at a Frequency of once every 12 months until two consecutive tests pass, at which time the 24 month '

test Freluency may be resumed.

(continued)

PBAPS UNIT 2 , B 3.6-4 Revision No. 6 ,

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Primary Containment '

B 3.6.1.1 BASES (continued) w REFERENCES N. t.

1. UFSAR, Section ttfr:ih

2. ,

• Letter G94-PEPR-183, Peach Bottom Improved Technical Specification Project Increased Drywell and i

$ i Suppression Chamber Pressure Analytical Limits, from G.V.

1994.

Kumar (GE) to A.A. Winter (PECO), August 23,

3. 10 CFR 50, Appendix J, Option B.

4 I Safety Evaluation by the Office of Nuclear Reactor i Regulation Supporting Amendment Nos.127 and 130 to Facility Operating License Nos. OPR-44 and DPR-56, dated February 18, 1988.

5.

NE194-01, Revision 0, " Industry Guideline for

Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."

6.

ANSI /ANS-56.8-1994, " Containment System Leakage Testing Requirements."

j 1

i h

PBAPS UNIT 2 B 3.6-5 Revision No. 6

4 PCIVs 1 B 3.6.1.3 3 BASES SURVEILLANCE SR 3.6.1.3.13 REQUIREMENTS (continued)

This SR ensures that. in case the non-safety grade instrument

! air system is unavailable, the SGIG System will perform its design function to supply nitrogen gas at the required

! pressure the SGIG System. for valve operators and valve-seals supported by i i The 24 month Frequency was developed '

! considering it is prudent that this Surveillance be performed only during a plant outage. Operating experience.

, has shown that these components will usually pass this

( Surveillance when performed at the 24 month Frequency. ,

i Therefore, the Frequency was concluded to be accept ~able from a reliability standpoint. j f

SR 3.6.1.3.14 a lyse n. erence

! less ha he ar based n lea e th is

eci _ d_le_a ge_ ea age throug l Si 4 t b_e s 1.5 setn We,n tested at3 P, (25 osig)

! s ensureCtha(risiv,eaxgg_e 1stroper4 accoGqtad f5r in

• de_ _ inho the ovusibrimtry containmenkleakakrate_. i

The RateFrequencyTesting Program. is required by the Primary-Containment L'eakagej

SR 3.6.1.3.15 i

i j Verifying the opening of each 6 inch and 18 inch primary J)

! containmentpurgevalveandeach18inchprimarycontainmentf $.

f exhaust valve is restricted by a blocking device to less f I i than or equal to the required maximum opening angle l.

specified in the UFSAR (Ref. 4) is required to ensure that (

i l

the valves can close under DBA conditions within the times ;J

in the analysis of Reference 1. If a LOCA occurs, the purg -

i and exhaust valves must close to maintain primary containment leakage within the values assumed in the accident analysis. At other times pressurization. concer:n, {l i are not present, thus the purge and exhaust valves can be i fully open. The 24 month Frequency is appropriate because

(;

the outage.

blocking devices may be removed during a refueling )

$ <{;

__ m e (continued 1 I 1

4 The analyses in Reference 1 are based on treatment of MStV leakage as a secondary contamment bypass leakage, i independent of a pnmary to secondary containment leakage anatyzed at 1.27 L,. In the Reference 1 analyse au 4 steam knes are assumed to leak at the TS Limit. This ensures tnat MSIV leakage is property accounted for in

" determining the overaHimpacts of pnmary containment leakage.

I PBAPS. UNIT 2 8 3.6-29'.

Revision No. 6 i

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4 4

. i -

Programs and Manuals l 5.5 5.5 Programs and Manuals 5.5.11  !

Safety Function Determination Procram (SFDpl (continued) 1.

(

A required system redundant to system (s) supported by  !

the inoperable support system is also inoperable; or -

2. l A required system redundant to system (s) in turn  !

supported inoperable;byorthe inoperable supported system is also 3.

A required system redundant to support system (s) for the supported systems (b.1) and (b.2) above is also inoperable. '

c.

The SFDP identifies where a loss of safety function exists.

If a loss of safety function is determined to exist by this program, the . appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

5.5.12 Primary Containment leakace Rate Testino 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, "Perf Test Program,". dated September ance-Based Containment Leak- l

~~

99 p , _

The basispeakloss calculated containment internal pressure for the desig of coolant accident,  !

P., is 49.1 psig.

The maximum allowable primary containment leakage rate, L,,

shall be 0.5% of primary containment air weight per day. at P,{

)s Leakage Rate acceptance criteria are:

a.

Primary 1.0 L,. Containment leakage rate acceptance criterion is 5 > l During the first unit startup following testing in 4 accordance with this program, the leakage rate acceptance '

criteria are s 0.60 L, for the Type B and Type C tests and 5 j 0.75 L, for Type A tests; .

~ (cordinued )

following excepton to NEl 94-01, Rev. O, " Industry Guidehne for y

implementng Performance-Based Opton of 10 CFR Part 50, AppendtxJ", Seebon 10.2:

a.

[

MSIV leakage is excluded from the combined total of 0.6 L, for the Type B and C tests PBAPS UNIT 3

~

5.0-17 Amenoment No. 214

+ - , -m ,

Programs and Manuals 5.5  !

5.5 Programs and Manuals 5.5.12 Primary Containment Leakaoe Rate Testino Procra1 (continued)

b. Air lock testing acceptance criteria are:

1) Overt!! air lock leakage rate is s 9000 scc / min when tes:ed at i P,. I j

i' he provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

1 I

c. MSIV leakage acceptance entena are as speerfied in SR 3.6.1.3.14.

PBAPS UNIT 3 5.0-18 Amenoment No. 214

Primary Containment B 3.6.1.1 i

BASES l

SURVEILLANCE SR 3.6.1.1.1 (continued)

REQUIREliENTS  !

I valve leakage (SR 3.6.1.3.14), does not necessarily result )

in a failure of this SR. The impact of the failure to meet these SRs must be evaluated against the Type A, B, and C acceptance criteria of the Primary Containment Leakage I Testing Program.J s left 1 kage pri' to M rs tartup I at er pefroriqing a r uired i kage test

< 0. L, for c bined ype B and leakage, required t e for av all Type leakag d < 0.75 L, At al other time between quired aakage ra tests, the acce ante crit ia is {

ah d on ann yerall T)Re A lea ge limi of s 1.0 L, s t

.0 D W otisite dose consecuences are y the assumptions of the safety analysis. The Frequency is  ;

t i required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.1.2 Maintaining the pressure suppression function of primary containment requires limiting the leakage from the drywell to the suppression chamber. Thus, if an event were to occur that pressurized the drywell, the steam would be directed through the downcomers into the ruperession pool. This SR ,

is a leak test that confirms that the bypass area between l i

the drywell and the suppression chamber is less than or '

equivalent to a one-inch diameter hole (Ref. 4). This ensures that the leakage paths that would bypass the suppression pool are within allowaole limits.

The leakage test is performed every 24 months. The 24 month Frequency was developed considering that component failures that might have affected this test are identified by other primary containment SRs. Two consecutive test failures, however, would indicate unexpected primary containment degradation; in this event, as the Note indicates, a test shall be performed at a Frequency of once every 12 months until two consecutive tests pass, at which time the 24 month test Frequency may be resumed.

(continued) i l

{

PBAPS UNIT 3 B 3.6-4 Revision No. 6

. 1 Primary Containment  !

B 3.6.1.1 l BASES (continued)

)'

REFERENCES 1. UFSAR, Section AOL

2.  !

Letter G94.-PEPR-183, Peach Bottom Improved Technical '

Specification Project Increased Drywell and Suppression Chamber Pressure Analytical Limits, from G.V.

1994.

Kumar (GE) to A.A. Winter (PFCO), August 23,

3. 10 CFR 50, Appendix J, Option B. l i

4.  !

Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment Nos. 127 and 130 to Facility Operating License Nos. DPR-44 and DPR-56, cated February 18, 1988.

5. NEI 94-01, Revision 0, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."

6.

ANSI /ANS-56.8-1994, " Containment System Leakage Testing Requirements."

l I

l l

i i

PBAPS UNIT 3 B 3.6-5 Revision No. 6

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.13 REQUIREMENTS (continued) This SR ensures that in case the non-safety grade instrument air system is unavailable, the SGIG System will perform its design function to supply nitrogen gas at the required pressure for valve operators and valve seals supported by the SGIG System. The 24 month Frequency was developed considering it is prudent that this Surveillance be  !

performed only during a plant outage. 0perating experience I has shown that these components will usually pass this Surveillance when performed at the 24 month Frequency.

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

SR 3.6.1.3.14 ea lyse in Re enc tha th cifi 1akrbasehn- At is j i

_l e age rate _.Reakage through h  ;

_MSIV mus e s 11.1 scfh Wen tested ap P. (25_psig) ___ ,

e all a a t The trequency is required by

~

Rate Testing Program.

e-Fn marf Mntainment LeR age GR 3.6.1.3.15 Verifying the opening of each 6 inch and 18 inch primary containment purge valve and each 18 inch primary containment exhaust valve is restricted by a blocking device to less than or equal to the required maximum opening angle specified in the UFSAR (Ref. 4) is required to ensure that the valves in the can close analysis under DBA of Reference 1. conditions within the times If a LOCA occurs, the purge and exhaust valves must close to maintain primary '

containment leakage within the values assumed in.the accident analysis. At other times pressurization concerns are not present, thus the purge and exhaust valves can be fully open. The 24 month Frequency is appropriate because the blocking devices may be removed during a refueling I outage.

(continued) '

independent of a pnmary to secondary contatnment teakage analyzec In the at 1.27 L,.

Reference 1 anatysis sN 4 '

steam bnes are assumed to leak at the TS Limit. This ensures that MS1V leakage is property account determining the overad impacts of pnmary containment leakage.

PBAPS UNIT 3 B 3.6-29 Revision No. 6