ML20195D648
| ML20195D648 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/11/1998 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20195D636 | List: |
| References | |
| NUDOCS 9811180117 | |
| Download: ML20195D648 (14) | |
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ARS 1 3.6.11 l
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' SURVEILLANCE REQUIREMENTS (continued) )
SURVEILLANCE FREQUENCY !
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SR 3.6.11.2 Verify, with the ARS air return fan damper closed and 92 days I with the bypass dampers open, each ARS fan motor j current is s 59.0 amps when the fan speed is 2 1174 rpm i L . and s 1200 rpm.
p SR 3.6.11.3 Verify, with the ARS fan not operating, each ARS motor 92 days operated damper opens automatically on an actual or l simulated actuation signal after a delay of2 9 seconds and s 11 seconds.
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i SR T3.6.11.4 Verify the check damper is open with the ARS fan 92 days j
!- operating.. l i 1 SR 3.6.11.5 Verify the check damper is closed with the ARS fan not 92 days l operating.
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I SR 3.6.11.6 Verify that each ARS fan is de-energized or is prevented 18 months from starting upon receipt of a terminate signal from the Containment Pressure Control System (CPCSk An0 lt eIlowe$ h 44sti vt'en reteW of E f%rt yem',ss,'ve %:-d~t, etCC l ca,A L - SR 3.6.11.7 Verify that4ARS fan motor-operated damper ;e;;; = is 18 months prevented from openint" On ::: !:t ^' 2 trr'-"^ _ g Se .lmm efa eignal and is allowed to open upon receipt of a start 14rt- FrJsti e-[<w J permissive from the 0;ntiT.:n! ." :xw; Os.::d de con %b+ frusvre, Sy=.TyPCS/. n d ai .v e (cit h D ,
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l Catawba Units 1'and 2 3.6.11-2 Amendment Nos.1 65
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ARS B 3.6.11 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.11.3 Verifying the OPERABILITY of the return air damper provides assurance that the proper flow path will exist when t io fan is started. This Surveillance also tests the circuitry, inclujing time delays to ensure the system operates properly. The Frequent,v of 92 days was developed considering the importance of the dampert their location, physical environment, and probability of failure. Ope ating experience has also shown this Frequency to be acceptable.
SR 3.6.11.4 and SR 3.6.11.5 Verifying the OPERABILITY of the check damper in the air return fan discharge line to the containment lower compartment provides assurance that the proper flow path will exist when the fan is started ana that reverse' flow can not occur when the fan is not operating. The Frequency of 92 days was developed considering the importance of the dampers, their location, physical environment, and probability of failure. Operating experience has also shown this Frequency to be acceptable.
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- d(t of SR 3.6.11.6 and SR 3.6.11.7 Ac.cnorgErl eris These SRs require verification that each ARS motor operated dam
/cebA to opengor is prevented from opening and each ARS farristrevented from !
startins: pen rece! ?! of Containment Pressure Control System startgind l Q " Y N'6 y , b C--
terminate signals. The CPCS is described in the Bases for LCO 3.3F, "ESFAS." The 18 month Frequency is based on operating experience 1
I which has shown it to be acceptable. -
femr.ru REFERENCES 1. UFSAR, Section 6.2.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
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- Catawba Units 1 and 2 B 3.6.11-5 Revision No.% l
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ATTACIDEENT 2 REPRINTED IMPROVED TECHNICAL SPECIFICATIONS PAGES FOR CATAWBA i
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ARS 3.6.11 l
SURVEILLANCE REQUIREMENTS (continued)
, l SURVEILLANCE FREQUENCY SR 3.6.11.2 Verify, with the ARS air return fan damper closed and 92 days with the bypass dampers open, each ARS fan motor current is s 59.0 amps when the fan speed is 21174 rpm and s 1200 rpm.
SR 3.6.11.3 Verify, with the ARS fan not operating, each ARS motor 92 days operated damper opens automatically on an actual or simulated actuation signal after a delay of2 9 seconds ' ,
and s 11 seconds. l SR 3.6.11.4 Verify the check damper is open with the ARS fan 92 days )
operating.
SR 3.6.11.5 Verify the check damper is closed with the ARS fan not 92 days l operating. l l
1 SR 3.6.11.6 Verify that each ARS fan is de-energized or is prevented 18 months from starting upon receipt of a terminate signal from the l Containment Pressure Control System (CPCS) and is
. allowed to start upon receipt of a start permissive from the CPCS.
SR 3.6.11.7 Verify that each ARS fan motor-operated damper is 18 months prevented from opening in the absence of a start permissive from the Containment Pressure Control System (CPCS) and is allowed to open upon receipt of a start permissive from the CPCS.
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l Catawba Units 1 and 2 3.6.11-2 Amendment Nos.
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ARS B 3.6.11 BASES i
l l SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.11.3 Verifying the OPERABILITY of the return air damper provides assurance
, that the proper flow path will exist when the fan is started. This l- Surveillance also tests the circuitry, including time delays to ensure the system operates properly. The Frequency of 92 days was developed
! considering the importance of the dampers, their location, physical environment, and probability of failure. Operating experience has also j shown this Frequency to be acceptable.
l SR 3.6.11.4 and SR 3.6.11.5
! Verifying the OPERABILITY of the check damper in the air return fan i discharge line to the containment lower compar'. ment provides assurance i that the proper flow path will exist when the fan is started and that reverse flow can not occur when the fan is not operating. The Frequency of 92 days was developed considering the importance of the dampers, i their location, physical environment, and probability of failure. Operating l experience has also shown this Frequency to be acceptable.
H SR 3.6.11.6 and SR 3.6.11.7 4
These SRs require verification that each ARS motor operated damper is allowed to open or is prevented from opening and each ARS fan is allowed to start or is de-energized or prevented from starting based on the presence or absence of Containment Pressure Control System start oermissive and terminate signals. The CPCS is describod in the Bases "or LCO 3.3.2, "ESFAS." The 18 month Frequency is based on operating experience which has shown it to be acceptable.
REFERENCES 1. .UFSAR, Section 6.2.
l 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
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i Catawba Units 1 and 2 B 3.6.11-5 Revision No.
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ATTACMGENT 3 DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION 1 o
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r Description of Proposed Changes ITS SR 3.6.11.6 states,
" Verify that each ARS fan is de-energized or is prevented from starting upon receipt of a terminate signal from the Containment Pressure Control System (CPCS) . "
Catawba is requesting that this SR be modified to also include a requirement to verify that the fan is allowed to start upon receipt of a start permissive signal from the CPCS. This will result in a SR 3.6.11.6 that requires testing of all relevant CPCS functions associated with allowing the fans to start and de-energizing or preventing them from starting. This results in a more restrictive SR 3.6.11.6.
ITS SR 3.6.11.7 states,
" Verify that ARS fan motor-operated damper closes or is prevented from opening upon receipt of a terminate signal and is allowed to open upon receipt of a start permissive from the Containment Pressure Control System (CPCS) . "
Catawba is requesting that this SR be modified to delete that portion of the surveillance pertaining to verification of damper closing. Also, the reference to receipt of a terminate signal is replaced with a reference to the absence of a start permissive signal. As shown in the Technical Justification below, this will make this SR consistent with the design of the CPCS at Catawba.
Corresponding changes to the Bases for SRs 3.6.11.6 and 3.6.11.7 are also being proposed as shown in Attachment 1.
Technical Justification The function of the CPCS is to protect the containment l building from excessive depressurization by preventing inadvertent actuation or continuous operation of the t
Containment Spray System and Air Return System when
- containment pressure is at or less than the CPCS permissive setpoint. The control scheme of the CPCS is comprised of eight independent control circuits (four per train), each having a separate and independent pressure transmitter and current alarm module. Each pressure transmitter monitors the containment pressure and provides input to its respective current alarm. The current alarms are set to inhibit or terminate the Containment Spray System and the Air Return System when containment pressure falls to or l
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beluw 0.25 psig. The alarm modules switch back to the .
permissive state (i.e., allow the Containment Spray System l and Air Return System to operate) when containment pressure is greater than or equal to 0.45 psig.
The CPCS control logic is shown in UFSAR Figure 7-14. (For l l reference, a copy'of this figure is included in this j amendment request package.) '
l As shown in the figure, the ARS fan receives both a start l permissive and a stop or terminate signal from the CPCS.
.Hence, it was concluded that in order to be consistent with the design of the CPCS, SR 3.6.11.6 should also require verification that the ARS fans are allowed to start upon receipt of a' start permissive. SR 3.6.11.6 does not presently contain this requirement. This requirement is, .
however, being verified by existing plant procedures. l Also, as shown in the figure, the ARS fan motor-operated !
'dsnper receives an open permissive from the CPCS, but it ;
does not receive a close or terminate signal. Hence, SR j 3.6.11.7, as presently written, does not reflect CPCS design '
in that no verification can be made of damper closure since the damper does not receive a close signal (the ARS design does not require motor-operated damper closure due to the fact that the fan will stop when required and the check l damper is closed when the fan is not operating).
l Verification can be made of the damper being prevented from opening. Also, SR 3.6.11.7 incorrectly makes reference to receipt of a terminate signal. The damper is actually prevented from opeaing in the absence of a start permissive.
The above requested changes are fully consistent with the CPCS_ design at Catawba. The requested change to SR 3.6.11.6 actually makes the-SR more restrictive, in that it imposes an additional requirement not presently contained in the ITS. The requested change to SR 3.6.11.7 aligns this SR with the design function of the CPCS.
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l No Significant Hazards Consideration Determination l
The following discussion is a summary of the evaluation of the changes contained in this proposed amendment against the 10 CFR 50.92(c) requirements to demonstrate that all three standards are catisfied. A no significant hazards consideration is indicated if operation of the facility in accordance with the proposed amendment would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated, or
- 2. Create the possibility of a new or different kind of '
accident from any accident previously evaluated, or
- 3. Involve a significant reduction in a margin of safety.
First Standard Implementation of this amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. Approval of this amendment will have no significant effect on accident probabilities or consequences. The CPCS is not an accident initiating system; therefore, there will be no impact on any ,
accident probabilities by the approval of this amendment.
The design of the CPCS is not being modified by this proposed amendment. The amendment merely aligns ITS surveillence requirements with the existing design and function of the system. Therefore, there will be no impact on any accident consequences.
Second Standard Implementation of this amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. No new accident causal mechanisms are created as a result of NRC approval of this amendment request. No changes are being made to the plant which will introduce any new accident causal mechanisms.
This mmendment request does not impact any plant systems that are accident initiators, since the CPCS is an accident mitigating system.
Third Standard l Implementation of this mnendment would not involve a
, significant reduction in a margin of safety. Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions I
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L during and'following an accident situation. These barriers l- '
. include'the fuel cladding, the reactor coolant system, and
[ - the containment system. The performance of these fission product barriers will not be impacted by implementation of
.. this proposed amendment. The CPCS is already capable..of i performing as designed.- No safety margins will be impacted.
Based upon the preceding analysis, Duke' Energy has concluded that the proposed amendment does.not involve a significant
. hazards consideration.
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l ATTACHMENT 5 l
ENVIRONMENTAL ANALYSIS l l
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Environmental Analysis Pursuant to 10 CFR 51.22(b), an evaluation of this license amendment request has been performed to determine whether or not it meets the criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) of the regulations.
This amendment to the Catawba ITS modifies SRs for the CPCS to align the requirements with the design and function of the system. Implementation of this amendment will have no adverse impact upon the Catawba units; neither will it contribute to any additional quantity or type of effluent being available for adverse environmental impact or personnel exposure.
It has been determined there is:
- 1. No significant hazards consideration,
- 2. No significant change in the types, or significant increase in the amounts, of any effluents that may be released offsite, and
- 3. No significant increase in individual or cumulative occupational radiation exposures involved.
Therefore, this amendment to the Catawba ITS meets the criteria of 10 CFR 51.22 (c) (9) for categorical exclusion from an environmental impact statement.
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