ML20151Y693

Proposed Tech Specs 3/4 6-5 & 6-20,amending Table 3.6-2, Containment Isolation Valves & Table 3.6-1, Bypass Leakage Paths to Auxiliary Bldg to Delete Flow Control Valves 77-16 & 77-17 & Penetration X-81,respectively

ML20151Y693
Person / Time
Site:	Sequoyah
Issue date:	04/28/1988
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20151Y690	List: ML20151Y688 ML20151Y693
References
TAC-R00339, TAC-R00340, TAC-R339, TAC-R340, NUDOCS 8805050071
Download: ML20151Y693 (9)

Text

.

~

TABLE 3.6-1

, ~

j SECONDARY C0tlTAltiMEtiT BYPASS LEAKAGE PAllts mmm! '

em 20 tn x RELEASE LOCATION 30, i PENETRATION .

BO c- Auxiliary Area 00 5 X-2A Personnel Lock Auxiliary Area

" Personnel Lock h X-2B Auxiliary Area om

~

X-3 Fuel Transfer Tube Auxiliary Area X-15 Letdown

@$ X-25A Pressurizer Gas Sample Auxiliary Area 04 Pressurizer Liquid Samole Auxiliary Area 88$ X-2SD X-268 Control Air Auxiliary Area Dy ILRT Auxiliary Area X-27C Auxiliary Area X-29 CCW Auxiliary Area X-30 Accumulator Fill Auxiliary Area X-34 Control Air Auxiliary Area X-35 CCW to Accumulators Auxiliary Area X-39A N2 Auxiliary Area i y X-39B N2 to Pressurizer Rellet Tank Auxiliary Area

> X-41 Normal RB Sump 3

Primary Water Auxiliary Area p X-42 Auxiliary Area m X-45 RC Drain Tank Auxiliary Area i X-46 RC Orain Tank Auxiliary Area X-47A Glycol Auxiliary Area X-470 Glycol Auxiliary Area X-50A CCW

, AuxiIiary Area X-508 CCW Auxiliary Area X-51 Fire Protection Auxiliary Area X-64 A/C Chilled Water (ERCW)

Auxiliary Area X-65 A/C Chilled Water (ERCW)

Auxiliary Area X-66 A/C Chilled Water (ERCW)

Auxiliary Area X-67 A/C Chilled Water (ERCW)

Auxiliary Area X-76 Service Air Auxiliary Area X-77 Demineralized Water Auxiliary Area X-78 Fire Protection %x !i 3;7y a re; v.oi or nry!g i e.a Auxiliary Area X-82 Fuel Pool Auxiliary Area i X-83 fuel Pool

-_a _ - --- - -_

i TA8'E 3.b-2 (Continued) ~

v. CONTAINMENT ISOLATION VALVES 9

E5 VALVE NUMBER FUNCTION MAXIMUM ISOLATION TIME (Seconds) l A. PHASE "A" ISOLATION (Cont.) l E

q 32. FCV-62-63 RCP Seals 10

,, 33. FCV-62-72 Letdown Line 10*#

34. FCV-62-73 ietdown Line 10*# R41

35. FCV-62-74 Letdown Line 10*#

36. FCV-62-77 Letdown Line 20

37. FCV-63-23 Accum to Hold Up Tank 10*

38. FCV-63-64 WDS N 2 to Accum 10*

39. FCV-63-71 Accum to Hold Up Tank 10*

46. FCV-63-84 Accum to Hold Up Tank 10*

41 FCV-68-305 WDS N 2 to PRT 10*

42. FCV-68-307 PP.T to Gas Analyzer 10*

l R2, 43. FCV-68-308 PRT to Gas Analyzer 10*

3-

44. FCV-70-85 CCS from Excess Lt On Hx 10*

i' 45. FCV-70-143 CCS to Excess Lt On Ib. 60*

y; 46. FCV-77-9 RCOT Pump Disch 10*

47. FCV-77-10 RCDT Pump Disch 10*

--48. FCV 77-!6 R41 RCOT te G2c a n2!yzer 10*

-- 4 9. FCY-77 RCDT to C;; "n;1yzcr 10*

d',n.a le r- ' 50. FCV-77-18 RCDT and PRT to V H 10*

4s A/<uu jf 51 FCV-77-19 RCOT and PRT to V H 108

52. FCV-77-20 N2 to RCDT 10*

53 FCV-77-127 Floor Sump Pump Disch 10*

54. FCV-77-128 Floor Sump Pump Disch 10*

55. FCV-81-12 Primary Water Makeup 10*

56. FCV-87-7 UHI Test Line 10*

57. FCV-87-8 UHI Test Line 10*

Pro 58. FCV-87-9 UHI Test Line 10*

flU 59. FCV-87-10 UHI Test Line 10*

[ H 60. FCV-87-11 UHI Test Line 10*

b [C

61. FCV-26-240 Fire Protection Isol. 20 N ,, II 62. FCV-26-243 Fire Protection ! sol. 20

~F,.I'

~ wO

TAhlE 3.6-1 M

S SECONDARY CONTAll#1ENI BYPASS LEAKAGE PAllis -

S -

E

, PENETRATION RELEASE LOCATION k" X-2A Personnel Lock Auxiliary Area X-28 Personnel Lock Auxiliary Area N

X-3 fuel Transfar Tube Auxiliary Area X-15 Letdown Auxiliary Area 4 X-25A Pressurizer Gas Sample Auxiliary Area X-2SD . Pressurizer 1.iquid Sample Auxiliary Area X-268 Control Air Auxiliary Area X-27C ILRT Auxiliary Area X-29 CCW Auxiliary Area Accumulator fill X-30 Auxiliary Area X-34 Control Air Auxiliary Area m X-35 CCW Auxiliary Area g' X-39A N2 to Accumulators Auxiliary Area -

3 X-398 N2 to Pressurizer Relief Tank Auxiliary Area, J, X-41 Normal RB Sump Auxiliary Area X-42 Primary Water Auxiliary Area

X-45 RC Drain Tank Auxiliary Area X-46 RC Drain Tank Auxiliary Area 4 X-47A Glycol AuxiIiary Area i X-478 Glycol Auxiliary Area X-50A CCW Auxiliary Area X-508 CCW , Auxiliary Area X-51 Fire Protection Auxiliary Area X-64 A/C Chilled Water (ERCU) Auxiliary Area

, X-65 A/C Chilled Water (ERCW) Auxiliary Area l X-66 A/C Chilled Water (ERCW) Auxiliary Area X-67 A/C Chilled Water (ERCW) Auxiliary Area-X-76 Service Air Auxiliary Area y X-77 Demineralized Water Auxiliary Area

, X-78 Fire Protection Auxiliary Area

-S! RC Drai T;;d ^ m!'iary "rca X-82 fuel Pool Auxiliary Area i

X-83 fuel Pool AuxiIiary Area I

O 4

TABLE 3.6-2 (Continued)

N -

@ CONTAINMENT ISOLATION VALVES S

E

, VALVE NUMBER FUNCTION MAXIMUM IS0i_ATION TIME (Seconds) b-'

A. PHASE "A" ISOLATION (Cont.)

32. FCV-62-63 RCP Seals 10

33. FCV-62-72 Letdown Line. 10*#

34. R29 FCV-62-73 Letdown Line 10*#

35. FCV-62-74 Letdown Line 10*#

36. FCV-62-77 Letdown Line 20 i

37. FCV-63-23 Accum to Hold Up Tank 10*

38. FCV-63-64 WDS 2N to Accus 10*

39. FCV-63-71 Accus to Hold Up Tank 10* R29

40. FCV-63-84 Accum to Hold Up Tank 10*

i 41. FCV-68-305 WDS N to PRT 10*

w 42. FCV-68-307 PRTt$GasAnalyzer 10*

} 43. FCV-68-308 PRT to Gas Analyzer 10*

, 44. FCV-70-85 CCS from Excess Lt On Hx 10*

4 o

45. FCV-70-143 CCS tc Excess Lt Dn Hx 60*

46. FCV-77-9 RCDT Pump Disch 10*

1

47. FCV-77-10 RC9T Pump Disch 10*

48. FCV-77-1E RCUT to C : .analy:cr 10* >

49. FCV-??-17 RCOT te Ca ^naly cr 10*

Rc= 4,,. 50. FCV-77-18 -

RCOT and PRT to V H 10*

4J Nemag 51. FCV-77-19 RCDT and PRT to V H 10*

52. FCV-77-20 N, to RCDT 10"

53. FCV-77-127 Floor Sump Pump Disch 10*

54. FCV-77-128 Floor Sump Pump Disch 10*

yl;- 55. FCV-81-12 Primary Water Makcup 10*

gy 56. FCV-87-7 UHI Test Line 10*

p !; 57. FCV-87-8 UHI Test Line 10*

g ': 58. FCV-87-9 UHI Test Line 10*

" g 59. FCV-87-10 UHI Test Line 10*

jF- 60. FCV-87-11 UHI Test Line 10*

61. FCV-26-240 Fire Protection Isol. 20

!s m p2. FCV-26-243 Fire Protection Isol. 20

l ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-07)

DESCRIPTION AND JUSTIFICATION FOR AMENDING TABLE 3.6-2, "CONTAINHENT ISOLATION VALVES,"

AND TABLE 3.6-1, "BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING" O

ENCLOSURE 2 i

Description of Change TVA proposes to modify SQN units 1 and 2 technical specifications to revise Table 3.6-2, "Containment Isolation Valves," to delete flow control l valves (FCVs) 77-16 and 77-17. Table 3.6-1, "Bypass Leakage Paths to the l Auxillary Building," is also amended to delete penetratico X-81 from the table.

i

-Reason for Change FCVs 77-16 and 77-17-are the containment isolation valves on the waste gas analyzer sample line from the reactor coolant drain tank (RCOT).

Engineering Change Notice (ECN) 5831 contains provisions to remove the valves and cap the sample line. This modification cannot be performed before the technical specification requirement for these valves is deleted. Penetration X-81 is deleted from Table 3.6-1 because a bypass leakage path to the auxiliary building through this penetration will not exist after the modification to remove FCVs 77-16 and 77-17 is completed.

Justification for Change FCVs 77-16 and 77-17 were determined to not be environa;entally qualified for their appilcation as containment isolation valves. When valve replacement was evaluated, it was determined that there were no .

requirements to continually monitor the RCOT cover gas and little information to be obtained from sampling the cover gas. The RCOT is described in section 11.2.3.1 of the SQN Final Safety Analysis Report (FSAR). The relative location of the RCDT in the waste disposal system is ,

shown in FSAR Figure 11.2.2-1. The waste gas analyzer is described in FSAR Section 11.3.2, and its associated flow diagrams are the 11.2.3

, series FSAR figures.

l The RCOT serves as a collection point for reusable reactor coolant grade water from inside containment. The collected water is normally routed to

! the chemical and volume control system (CVCS) holdup tanks (HUTS) or the tritiated drain collector tank for processing. In this case, water

! chemistry is the concern, not cover gas chemistry.

The RCOT is operated with a nitrogen cover gas. The cover gas is provided i

by the nitrogen supply system described in FSAR Section 11.3.2. Also, the j RCDT is normally aligned to the waste gas vent header (FSAR Figure 11.2.2-1). This alignment provides the ability to sample and analyze the RCOT cover gas. This is done by sampling the waste gas decay tank which is aligned to the waste gas compressors. The RCDT cover gas could also be sampled from the pressurizer relief tank (PRT) because pressure control valve (PCV)68-301 (f3AR Figure 5.1-1) is normally open and the two cover gas atmospheres are in communication. Therefore, for normal operation the ability exists to sample the RCOT cover gas without relying on the gas analyzer sample line.

For postaccident conditions, the cover gas chemistry of the RCOT is not needed. No information of value would be obtained. In addition, all of the sampling lines isolate on a phase A isolation signal, and sampling is not possible.

In summary, the RCOT cover gas is not routinely sampled. Provisions do exist for sampling the cover gas, if necessary, without relying on the waste gas analyzer sample line from the RCDT. Under accident conditions, the sampling line is isolated, and RCDT cover gas chemistry is not determined. Therefore, instead of replacing the containment isolation valves, the valves will be removed and the sample line isolated.

Containment integrity will be provided by a welded cap in tne annulus on a short section of the sample line after FCVs 77-16 and 77-17 are no longer required as containment isolation valves. A "mini" Type A test (Integrated Containment Leakage Rate) will be performed as a postmodification test to ensure containment leakage rates remain acceptable. The penetration will then ce included in the scope of the Type A testing required by surveillance requirement 4.6.1.2. Because the penetration will terminate at the welded cap in the annulus, the potential for bypass leakage to the auxiliary building is eliminated. This allows penetration X-81 to be deleted from Table 3.6-1.

In conclusion, FCVs 77-16 and 77-17 may be removed because sampling of the RCDT cover gas is not prevented by removing the sample line to the waste gas analyzer. The valves will not be required for containment isolation because integrity will be provided by a welded cap on the sample line in the annulus. This allows the valves to be deleted from Table 3.6-2.

Terminating the line in the annulus eliminates the potential bypass leakage path to the auxiliary building through this penetration. This allows the deletion of penetration X-81 from Table 3.6-1.

1 l

l l

l

,s.A - _ s -a m

9 ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLtNT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-88-07)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS e

i .

1

}

l 5

E vn,-. , v.m----~,--- , , - , , , ,--,---,v.,,,_,,n., ,n.- m-,.cn ,,,,,.,--.,-n-,,,,,._,,--- - - - - -,,- ,,,,-n,. , , .- . . . ,~., ,,- . . ~ - - , - - , . .- e

' ~

ENCLOSURE 3 1 Significant Hazards Evaluat hn i TVA has evaluated the proposed technical specification change and determined that it does not represent a significant hazards consideration based on criteria estab11shed in 10 CFR 50.92(c). Operation of SQN in accordance with the proposed amendment will not:

1. Involve a significant increase in the probability or consequences ?f

...i accident previously evaluated. Removal of containment isolation valves FCV-77-16 and FCV-77-17 and capping of the RCOT to the gas analyzer line will not degrace the function of any safety-related system. The ability exists.to sample the cover gas, if needed, without relying.on the waste gas analyzer sample line. Additionally, the valves to be removed are not envh onmentally quallfled and as such cannot be guaranteed to retain position for containment isolation purposes. Permanent closure of the line will ensure containment integrity. This will be verified by periodic Type A containment leak rate testing. The removal of these valves allows them to be' deleted from Table 3.6-2. -Because the penetration will terminate in the annulus, the potential bypass leakage path associated with it is eliminated and the entry is rec.oved from Table 3.6-1. Because the function of all systems will remain intact and containment isolation is. ensured, there is no increase in the probability or consequences of a previously evaluated accident.

4

2. Create the possibility of a new or different kind of accident from any previously analyzed. Because the basic control, logic, and function of all safety-related equipment are unchanged and there is no ,

potential for abnormal plant conditions because of the removal of the valves and capping of the line, the possibility of a new accident is not created.

3. Involve a significant reduction in a margin of safety. The margin of safety for the SQN isolation scheme is established by the specification of containment isolation valves in Technical Specification Table 3.6-2. Capping of the sample line following removal of containment isolation valves FCV-77-16 and FCV-77-17 will ensure that containment isolation for that line is maintained at all times. This is verified by periodic Type A containment leak rate l

testing. Therefore, removal of these valves from Table 3.6-2 will not reduce the margin of safety of the containment isolation plan. The deletion of penetration X-81 from Table 3.6-1 will also not reduce the margin of safety. The entry is deleted to rt.flect that a bypass leakage path is no longer associated with this penetration because the line is capped in the annulus.

l I

l l

• ~ ~ ' ^

• J _ -.,-_-,.~~-----.----M

'