ML20151Y365

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Proposed Final TS Pages for License Change Applications ECR 96-02324 & 98-00499,revising MSIV Leakage & Safety Relief Valve Surveillance Testing
ML20151Y365
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 09/11/1998
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20151Y364 List:
References
NUDOCS 9809180213
Download: ML20151Y365 (22)


Text

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l ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 LICENSE CHANGE APPLICATION ECR 96-02324 l

9009180213 900911 PDR ADOCK 05000277 P

PDR 5,

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Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Safety Fur.ction Determination Proaram (SFDP) (continued) 1.

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

A required system redundant to system (s) in turn supported by the inoperable supported system is also inoperable; or 3.

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

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 i

the LCO in which the loss of safety function exists are required to be entered.

5.5.12 Primary Containment Leakaae 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, as modified by the following exception to NEI 94-01, Rev. O, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Section 10.2:

a.

MSIV leakage is excluded from the combined total of 0.6 L.

for the Type B and C tests.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 49.1 psig.

The maximum allowable primary containment leakage rate, L., at P.,

shall be 0.5% of primary containment air. weight per day.

Leakage Rate acceptance criteria are:

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 criteria are s 0.60 L. for the Type B and Type C tests and s 0.75 L for Type A tests; 4

(continued)

PBAPS UNIT 2 5.0-17 Amendment No.

Programs and Manuals 5.5

)

5.5 Programs and Manuals 5.5.12 Primary Containment teakaae Rate Testina Proaram (continued) 1 b.

Air lock testing acceptance criteria are:

1)

Overall air lock leakage rate is s 9000 scc / min when tested at 2 P..

c.

MSIV leakage acceptance criteria are as specified in SR 3.6.1.3.14.

The 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 j

Containment Leakage Rate Testing Program.

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PBAPS UNIT 2 5.0-18 Amendment No.

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Primary Containment B 3.6.1.1 BASES SURVEILLANCE SR 3.6.1.1.1 (continued)

REQUIREMENTS l

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 Rate l

Testing Program.

At s 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis.

The

. Frequency is required by the Primary Containment Leakage Rate Testing Program.

l 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 suppression pool.

This SR is a leak test that confirms that the bypass area between l

the drywell and the suppression chamber is less than or i

l 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.

l The leakage test is performed every 24 months. The 24 month l

Frequency was developed considering that component failures l

that might have affected this test are identified by other l

primary containment SRs.

Two consecutive test failures, l

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) 1.

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PBAPS UNIT 2 B 3.6-4 Revision No.

Primary Containment B 3.6.1.1 BASES (continued)

<l REFERENCES 1.

UFSAR, Section 14.9.

2.

Letter G94-PEPR-183, Peach Bottom Improved Technical Specification Project Increased Drywell and Suppression Chamber Pressure Analytical Limits, from G.V. Kumar (GE) to A.A. Winter (PECO), August 23, 1994.

3.

10 CFR 50, Appendix J, Option B.

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, dated 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."

7.

Peach Bottom Atomic Power Station Evaluation for Extended Final Feedwater Reduction, NEDC-32707P, Supplement 1, Revision 0, May, 1998.

PBAPS UNIT 2 8 3.6-5 Revision No.

~

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. Operating experience 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 Leakage through each MSIV must be s 11.5 scfh when tested at t P. (25 psig). The analyses in Reference 1 are based on treatment of MSIV leakage as a secondary containment bypass leakage, independent of a primary to secondary containment leakage analyzed at 1.27 L.. In the Reference 1 analysis all 4 steam lines are assumed to leak at the TS Limit. This ensures that MSIV leakage is properly accounted for in determining the overall impacts of primary containment leakage. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

ER 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 devict u less than or equal to the required maximum opening angle specified in the UFSAR (Ref. 4) is required to ensure that the valves can close under DBA conditions within the times in the analysis of Reference 1.

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 outage.

(continued)

PBAPS UNIT 2 B 3.6-29 Revision No.

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

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

A required system redundant to system (s) in turn supported by the inoperable supported system is also inoperable; or-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 Leakaae 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, as modified by the following exception to NEI 94-01, Rev. O, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Section 10.2:

a.

MSIV leakage is excluded from the combined total of 0.6 L.

for the Type B and C tests.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 49.1 psig.

The maximum allowable primary containment leakage rate, L., at P.,

shall be 0.5% of primary containment air weight per day.

Leakage Rate acceptance criteria are:

a.

Primary Containment leakage rate acceptance criterion is s 1.0 L..

During the first unit startup following testing in i

accordance with this program, the leakage rate acceptance criteria are s 0.60 L. for the Type B and Tyr-e tests and s l

0.75 L. for Type A tests; (continued)

PBAPS UNIT 3 5.0-17 Amendment No.

i

Programs and Manuals 5.5 i

5.5 Programs and Manuals 5.5.12 Primary Containment Leakaoe 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 a P..

c.

MSIV leakage acceptance criteria are as specified in SR 3.6.1.3.14.

The provisions of SR 3.0.2 do not apply to the test frequencies j

specified in the Primary Containment Leakage Rate Testing Program.

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

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1 PBAPS UNIT 3 5.0-18 Amendment No.

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Primary Containment i

8 3.6.1.1 BASES SURVEILLANCE SR 3.6.1.1.1 (continued)

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 these SRs must be evaluated against the Type A, B, and C acceptance criteria of the Primary Containment Leakage Rate l

Testing Program. At s 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis.

The Frequency is 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 i

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 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)

PBAPS UNIT 3 8 3.6-4 Revision No.

. - - =..

Primary Containment B 3.6.1.1 BASES (continued)

l. REFERENCES 1.

UFSAR, Section 14.9.

2.

Letter G94-PEPR-183, Peach Bottom Improved Technical Specification Project Increased Drywell and Suppression Chamber Pressure Analytical Limits, from G.V. Kumar (GE) to A.A. Winter (PECO), August 23, 1994.

3.

10 CFR 50, Appendix J, Option B.

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, dated 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."

7.

Peach Bottom Atomic Power Station Evaluation for Extended Final Feedwater Reduction, NEDC-32707P, Supplement 1, Revision 0, May, 1998.

PBAPS UNIT 3 B 3.6-5 Revision No.

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.

Operating experience 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 Leakage through each MSIV must be s 11.5 scfh when tested at

t P. (25 psig). The analyses in Reference 1 are based on treatment of MSIV leakage as a secondary containment bypass leakage, independent of a primary to secondary containment leakage analyzed at 1.27 L.

In the Reference 1 analysis all 4 steam lines are assumed to leak at the TS Limit. This ensures that MSIV leakage is properly accounted for in determining the overall impacts of primary containment leakage.

The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 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 can close under DBA conditions within the times in the analysis of Reference 1.

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 outage.

(continued)

PBAPS UNIT 3 0 3.6-29 Revision No.

ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 LICENSE CHANGE APPLICATION 98-00499 l

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i SRVs and SVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift setpoints In accordance of the required SRVs and SVs are as with the follows:

Inservice Testing Program Number of Setpoint SRVs (osia) 4 1135 i 11.0 4

1145 i 11.0

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3 1155 i 12.0 Number of Setpoint SVs (osia) 2 1260 t 13.0 SR 3.4.3.2 Verify each required SRV actuator strokes 24 months when manually actuated in the depressurization mode.

PBAPS UNIT 2 3.4-9 Amendment No.

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4 ECCS -Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR -3.5.1.12 Verify each ADS valve actuator strokes when 24 months manually actuated in the depressurization mode.

4 PBAPS UNIT 2 3.5-7 Amendment No.

SRVs and SVs B 3.4.3 BASES l

SURVEILLANCE SR 3.4.3.2 REQUIREMENTS (continued)

The pneumatic actuator of each SRV valve is stroked.to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes.

Second stage pilot rod movement is determined by the measurement of actuator rod l

travel.

The total amount of movement of the second stage l

pilot rod from the valve closed position to the open position shall meet criteria established by the SRV f

supplier.

If the valve fails to actuate due only to the failure of the solenoid, but is capable of opening on overpressure, the safety function of the SRV is considered OPERABLE.

Operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling outage. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

NEDC-32183P, " Power Rerate Safety Analysis Report for Peach Bottom 2 & 3," May 1993.

2.

UFSAR, Chapter 14.

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PBAPS UNIT 2 B 3.4-18 Revision No.

ECCS -0psrating 8 3.5.1 BASES SURVEILLANCE SR 3.5.1.11 (continued)

REQUIREMENTS pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

l This SR is modified by a Note that excludes valve actuation.

This prevents an RPV pressure blowdown.

SR 3.5.1.12 The pneumatic actuator of each ADS valve is stroked to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes. Second stage pilot rod 1

movement is determined by the measurement of actuator rod travel. The total amount of movement of the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the S/RV i

supplier. SRs 3.3.5.1.5 and 3.5.1.11 overlap this Surveillance to provide testing of the SRV depressurization mode function.

Operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

(continued) j i

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PBAPS UNIT 2 B 3.5-16 Revision No.

]

~

ECCS -Operating.

B 3.5.1 BASES (continued)

REFERENCES 1.

UFSAR, Section 6.4.3.

2.

UFSAR, Section 6.4.4.

3.

UFSAR, Section 6.4.1.

4.

UFSAR, Sections 4.4.5 and 6.4.2.

5.

UFSAR, Section 14.6.

6.

10 CFR 50, Appendix K.

7.

NEDC-32163P, " Peach Bottom Atomic Power Station Units 2 and 3 SAFER /GESTR-LOCA Loss of Coolant Accident Analysis," January 1993.

8.

10 CFR 50.46.

9.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

10.

UFSAR, Section 10.17.6.

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PBAPS UNIT 3 B 3.5-17 Revision No.

SRVs and SVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1

. Verify the safety function lift setpoints In accordance of the required SRVs and SVs are as with the follows:

Inservice Testing Program Number of Setpoint SRVs (osia) 4 1135 i 11.0 4

1145 i 11.0 3

1155 i 12.0 Number of Setpoint j

SVs (osia) 2 1260 i 13.0 4

SR 3.4.3.2 Verify each required SRV actuator strokes 24 months when manually actuated in the depressurization mode.

l PBAPS UNIT 3 3.4-9 Amendment No.

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.12 Verify each ADS valve actuator strokes when 24 months manually actuated in the depressurization mode.

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PBAPS UNIT 3 3.5-7 Amendment No.

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SRVs and SVs s

B 3.4.3 BASES e

SURVEILLANCE SR 3.4.3.2 REQUIREMENTS (continued)

The pneumatic actuator of each SRV valve is stroked to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes.

Second stage pilot rod movement is determined by the measurement of actuator rod travel. The total amount of movement of the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the SRV supplier.

If the valve fails to actuate due only to the failure of the solenoid, but is capable of opening on overpressure, the safety function of the SRV is considered OPERABLE.

Operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling outage. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

NEDC-32183P, " Power Rerate Safety Analysis Report for Peach Bottom 2 & 3," May 1993.

2.

UFSAR, Chapter 14.

]

PBAPS UNIT 3 B 3.4-18 Revision No.

ECCS-Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.11 (continued)

REQUIREMENTS pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.

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

This SR is modified by a Note that excludes valve actuation.

This prevents an RPV pressure blowdown.

SR 3.5.1.12 The pneumatic actuator of each ADS valve is stroked to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes.

Second stage pilot rod movement is determined by the measurement of actuator rod travel. The total amount of movement of the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the S/RV supplier.

SRs 3.3.5.1.5 and 3.5.1.11 overlap this l

Surveillance to provide testing of the SRV depressurization mode function.

Operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

l

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(continued) l l

PBAPS UNIT 3 B 3.5-16 Revision No.

l

ECCS-Operating B 3.5.1 BASES (continued)

REFERENCES 1.

UFSAR, Section 6.4.3.

2.

UFSAR, Section 6.4.4.

)

3.

UFSAR, Section 6.4.1.

4.

UFSAR, Sections 4.4.5 and 6.4.2.

5.

UFSAR, Section 14.6.

6.

10 CFR 50, Appendix K.

7.

NEDC-32163P, " Peach Bottom Atomic Power Station Units 2 and 3 SAFER /GESTR-LOCA Loss of Coolant Accident Analysis," January 1993.

8.

10 CFR 50.46.

9..

Memorandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), " Recommended Interim Revisions to LCOs for ECCS-Components," December 1, 1975.

10.

UFSAR, Section 10.17.6.

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I PBAPS UNIT 2 B 3.5-17 Revision No.

.