ML20207K104

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Proposed Tech Specs Improving Licensing & Design Basis for Isolation of FW Penetrations
ML20207K104
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 03/04/1999
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CENTERIOR ENERGY
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ML20207K097 List:
References
NUDOCS 9903170051
Download: ML20207K104 (15)
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Attachment 2 Programs and Manuals PY-CEl/NRR-2370L Page 1 of 4 e-b-) ?Mp pr ovicle d -

Er 5.5 Programs and Manuals s4r Qd, % A pg 5.5.10 Safety Function Determinatio The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this vogram, the appropriate Conditions and Required Actions of the _C0 in which the loss of safety function exists are required to be entered.

5.5.11 Technical Soecifications (TS) Bases Control Proaram This Jrogram provides a means for processing changes to the Bases for t1ese TS.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews. -
b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:
1. a change in the TS incorporated in the license: or  :
2. a change to the.USAR or Bases that involves an -

unieviewed safety question as defined in 10 CFR 50.59.  !

c. The Bases Control Program shall contain provisions to' ensure that the Bases are maintained consistent with the USAR.
d. Proposed changes that meet the criteria of Saecification 5.5.11.b.1 or Specification 5.5.11.b.2 above i slall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

5.5.12 Primary Containment Leakace Rate Testina Proaram A program shall be established to implement the leakage rate testing of the primary containment as required by 10 CFR 50.54(o) and 10 CFR 50. Appendix J. Option B as modified by a) proved exemptions. This program shall be in accordance wit 1 the guidelines contained in Regulatory Guide 1.163. "Perforrrance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions: ,

(continued) I PERRY - UNIT 1 5.0-15 Amendment No. 49, 86 9903170051 9903044 gDR ADOCK 0 j0;

  • NE R 2370L Programs and Manuals Page 2 of 4 5.5 OJ , 5.5 , Programs and Manuals 5.5.12 1 Pi'imary Containment Leakaoe Rate Testino Prooram (continued)

BN-TOP-1 methodology may be used for Type A tests. 1 The corrections to NEI 94-01 which are identified on the Errata Sheet attached to the NEI letter. "A)pendix J i Workshop Questions and Answers." dated Marc 119.1996,are Asiderad to_be an ntegral part of NEI 94-01.

. L. 1 5 J e f fro h W = C met >ea caTcuratea primaryIontainment internal pressure for the design basis loss of coolant accident. P, is 7.80 psig. i i

i The maximum allowable primary containment leakage rate. L be 0.20% of primary containment air w  ;

calculated peak containment (P.) .

pressure. eight per day at; Leakage rate acceptance criteria are: i

a. Primary containment leakage rate acceptance criterion is  !

< 1.0 L However, during the first unit startup following i

~ testing,.performed in accordance with this Program, the i

'l leakage rate acce t s .) and Type C tests,ptance and s 0.75 L,criteria are < 0.6 L,A tests:for the Ti for the Type '

b. Air lock testing acceptance criteria are: '
1)  :

Overall air lock leakage rate is s 2.5 scfh when tested at a P,. - (;

2) For each door, leakage rate is s 2.5 scfh when the gap between the docr seals is pressurized to a P,.  ;

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

l, The provisions of SR 3.0.3 are ap311 cable to the Primary i Containment Leakage Rate Testing 3rogram.

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- Th c 4 I% t hda.Nen ck 4 vd.<4 fn h. Fu b fu-mw t.as am. + W pe- A h vta-Tu+ '

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m PERRY - UNIT 1 5.0-15a Amendment No. 86 l

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Attachment 2 PY-CEl/NRR.2370L me Page 3 of 4 PY- RR-2352L e40 Primary Containment-0perating i

! B 3.6.1.1 I I

BASES L l l

SURVEILLANCE SR 3.6.1.1 (continued)

REQUIREMENTS c.

l Sections III.A.1(d). III.A.5(b)(2). III.B.3 and III.C.3 - The main steam lines between the inboard and outboard MSIVs (including the volume up to the outboard MSIV before seat drain line valves) are not recuired to be vented and drained for Type A testing anc the main steam line isolation valve leak rates are exempted from inclusion in the overall integrated primary containment leak rate and the combined local leak rate (Reference 8).

d. Section III.D.1(a) - The third Type A test for each 10-year service period is not required to be conducted when the plant is shutdown for the 10-year plant inservice inspection (Reference 8).

e.

Section III.D.3 - Type C local leak rate testing may be performed at other convenient intervals in addition to shutdown during refueling, but at intervals no  !

' As lEft leakage pri'or to t7e first startup after performing a required leakage test is required to be < 0.6 L for combined Type B and Type C leakage, and s 0.75 L,,for overall Type A leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of < 1.0 L . At < 1.0 L the offsite dose consequences are bounded b'y the assumpti,ons of the safety analysis.

REFERENCES 1. USAR Section 6.2.

2. USAR. Section 15.6.5.
3. 10 CFR 50. Appendix J. Option B.
4. PY-CEI/NRR-1510L. dated June 24, 1992.
5. Letter from NRC (B.J. Youngblood) to CEI (M.R.

Edelman) " Performance of the Preoperational Containment Integrated Leak Rate Test - Perry Nuclear i

Power Plant. Unit 1." dated June 10. 1985.

(r,entinued)

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PERRY - UNI' O rr, .%m j -

g,f',g c.pv Joh e. A -

.6-5 Revision No. ~.

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. - -. . - . . . _ . . . - _ . . . .-. .- . .= . - .

Attachment 2 CEl/NRR-2370L 23S2L Primary Containment p BASES REFERENCES _

(continued) 6.

PNPP Safety Evaluation Report Supplement 7. Section 6.2.6 " Containment Leakage Testing," November 1985.

7.

Letter from NRC (T. Colburn) to CEI (A. Kaplan),

" Exemption January from 10 CFR Part 50 Appendix J . dated 22, 1988,

8. Letter from NRC (J. Ho Company (D. Shelton). pkins) to Centerior Services

" Issuance of Exemption from the Requirements of 10 CFR Part 50, Appendix J - Perry Nuclear Power Plant Unit 1", dated December 4, 1995.

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  • PERRY - UNIT 1 B 3.6-6 Revision No. '.

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$'N TABLE 1.8-1 (Continued) $

.m{h '

9., E Regulatory Guide (Rev. ;RRRC Category)

Decree of Conformance Reference U 5

c-1.149 - (Revision 1 - 4/87)

Simulation facilities for use in PNPP conforms to this guide. -

operator license examinations at nuclear power plants.

1.150 - (Revision 1 - 2/83) i Ultrasonic testing of reactor vessel PNPP conforms to the alternative method - '

welds during preservice and inservice presented in Appendix A of this guide.

examinations c

1.155 - (Revision 0 - 6/88)

Station Blackout PNPP conforms to this guide.

$ 15.8.2, 15H 1.163 - (Revision 0 - 9/95)

Performance-Based Containment Leak-Test PNPP complies with this guide with the Program following exceptions:

EN-TOP-1 methodology may be used for Type A tests.

The corrections to NEI 94-01 that are ," g9- l

.b'28 identified on the Errata Sheet attached to the NEI letter, " Appendix J Workshop

_g gg.g- ;3 day.g M Questions and Answers," dated March 19, $

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'A N f4*'Ad** # 1996, are considered to be an integral E

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Attachment 3 PY-CEl/NRR-2370L Page 2 of 11 RR-2;

][vtSAJh e 18 Should a break occur in a feedvater line, th' control closure check valves prevent significant loss of re tor coolant inventory and provide immediate isolation.

The outermost .

motor operated valve does not close automatically upon \

i occurrence of a protection system signal since, during a Lc0A accident,O enintonnage of reactor coolant makeup from all source: 9[sctu tag non-<ar +v so urcsO, desiraole.

Inis valve, Tovever, can be remotely hi b closed from the control room to provide long ter$ e h b protection when, in the judgment of the operator, continued .

makeup from the feedvater system is no longer necessary. In 3 ^ 5 8#"

addition, after feedvater flow terminates, the operator vill initiate the feedvater leakage control system (refer to Section 6.9) to provide a positive water seal on the tenletica  ;

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2. High Pressure Core Spray Line (P410/P411) l i

The high pressure' core spray line penetrates both the containment and the dryvell and connects to the reactor pressure vessel.

Isolation is provided by a hydraulically ,

testable check valve inside the dryvell and a motor operated gate valve as close as possible to the outside of the containment vall. This gate valve maintains long term leakage control.

Position indication for the hydraulically testable check valve is provided in the control room. The gate valve is automatically and remote-manually operated. A guard pipe is not necessary since the high pressure co;e spray fluid is at an energy ?.evel during system operation that containment overpressurization cannot result should the line break between the containment and the dryvell.

6.2-89 l

F

Attachment 3 1 PY-CEl/NRR-2370L Page 3 of 11 chm PY- R-2352L ge 19 o insert Page 6.2-89 These check valves are tested in accordance with Technical Specification 5.5.6, inservice Testing Program, to verify this closure function.

tere =/.9 .:nt:sc:e;ec.:h:2 v 90: ^r. .^;?er"- J avempSr. Er methorW 6: emet Ney et!!!:: On ?!!c netr 'ertu g.

Ty "vi'n; ;l;;;' n;pc 44ag cm te verify th;;. y;;pr c'erure.

t! n Of 90 yd;; #e nar *= 'nt?~ ice Tert!ng insert 1 Power to these motor operated valves can be provided from an alternate division under administrative controls, if necessary following a LOCA.

Insert i

... seat, stem and bonnet of the motor operated valve in each line. The check valves, I

! coupled with the sin 0!e motor-operated high integrity leakage protection gate valve on each line, provides an acceptable configuration for the feedwater lines.

A branch line connects to the Feedwater line outboard of the second Feedwater chec valve, which is outboard of the containment. This branch line provides the pathway [

for RWCU water and RHR shutdown cooling water to retum to the reactor vessel. For the

! RHR shutdown cooling retum iine, a safety-related globe valve is treated as a high integrity containment isolation valve, similar to the Feedwater gate valves. The RHR system " outboard" of the globe valve is also treated as a closed system outside of j

containment, to control any leakage. For the RWCU return line, the piping " outboard" of '

the RWCU branch line check valve leads directly back to containment penetration P132, and is ASME Code Class 2, Seismic Category 1, protected from pipe whip, missiles and )

jet forces, and analyzed for " break exclusion". This line is also treated as a closed system outside of containment (see Table 6.2-40 for testing details on containment penetrations). The design of these branch lines also provides an acceptable configuration.

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Attachment 3 PV-CEl/NRR-2370L Page 4 of 11 hmen PY- R-2352L

. P e 31 o l TABLE 6.2-32 (Continued)

NOTES: (Continued)

_ Signal Description

9. ' Standard (Std) closure time, based upon nominal pipe diameter, is approximately 4 inches / minute12 for inches / minute for gate valves and approximately globe valves.

butterfly valves is 30 to 60 seconds.The standard closure time for 10.

AC motor operated valves required for isolation functions are powered from the ac standby power buses.

valves are powered from the batteries. DC operated isolation 11.

Testable check valves are designed for remote opening with zero differential pressure across the valve seat.

The valves close under reverse positioned flow conditions, even if the test to open. switch is The valves open when pump pressure exceeds reactor pressure, even if the test switch is positioned to close.

12. Deleted 13.

Main steam linetoisolation be de-energized close. valves require that both solenoid pilots  ;

to close valves when both pilots are de-energized. Accumulator Voltage failure air prl at only one pilot does not cause valve closure.

These valves are j designed to close fully in 2.5 to 5 seconds (see Section 5.4.5.3) .

14.

During reactor operation, a blind flange is installed on the outboard end of the transfer tube as the containment boundary.

15. Deleted
16. This receives a Type B test.

17 Deleted 18.

Valve stroke times are specified as Unit 1/ Unit 2. (If only one time is indicated, it applies to both units.)

19.

The ECCS response time requirement for these injection valves is met with the valves partially opened.

are for full (100%) valve strokes. Times shown in this table  :

1 l 2 D. k kW W 2.1. A L wrt 6.2-216 Revision 8 Oct. 1996

l Attachment 3 j

PY-CEl/NRR-2370L Page 5 og 33 chm i

W gA*2352L

.a nsert Pageeg.ggg

20. Division 3 power is also available by post accident operator manual action (procedurally controlled).
21. fa ?,pp; .S J excr?!!:r f;rThe Feedwater check valves der"~er".; M :

.wAme. utilize an attemate testing methodology r ' ;;!15; "%2! ' . ,p;;'!:r. Of th;

te; ;,;;'; per the Inservice Testing Program to verify their proper closure.

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4 Attachment 3 6d 2352L TABLE 6.2-40 (Continued)

M: (Continuedi _

.h urf ).

5. -

i e feedwater lines are sealed post-LOCA with water from the feedwater leakage control system (FWLCS).

tested as follows. Feedwater lines wil The inboard and outboard check valves 1 be tested with water to a pressure not less than 1.10 P .

Acceptable check valve leakage is 1 gpm per valve. The o-rd gate valve stems and bonnets will be Type 'C' tested

  • h air. A high pressure (1,000 psig) water leak tes  ;

stem and bonnet may be performe f the outboard gate valve the Type 'C' air test, wi s an alternative test in lieu of Water leakage throug ero water leakage being acceptable.

1 0.60 L, Type B e check valves is not included in the C test totals. Also, if a Type 'C' air is pe test with bonn d, air leakage through the gate valve stem and will be eliminated.

nsidered bypass leakage. Gate valve through-seat leakage is not 6.

System remains water filled post-LOCA.

water to a pressure not less than 1.10 Isolation valve tested with P,.

not included in 0.60 L, Type B and C test totals. Isolation valve lea 7

The redund Ins *#I consist of containment isolation provisions for this penetration /

inflatable seal and an isolation valve. A si active failure can be accomodated. For the leak

. function, which is applicable to the s ontrol

' annulus, the line to the annu Ine from outer door to closed system to se s designed to standards for a

. containment. The closed system is missile ed, Seismic Category I, Safety Class 2, and has a rature and pressure rating in excess of that for the 6.2-250 Revision 8 Oct. 1996

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Attachment 3 PY-CEl/NRR-2370L Page 7 of11 e

PY 2352L 43 o l

l Insert for NOTE 5 Page 6.2-250 The Appendix J Type 'C' test for the Feedwater lines is provided by the Type 'C' hydrostatic tests performed on the long term, high integrity leakage protection valves, i.e., the motor operated gate valves (B21-F065A/B). Water leakage from the Feedwater Leakage Control System (FWI.CS) piping, and from the bonnet, stem and seat of the motor operated gate valves, are controlled under the Primary Coolant Sources Outside Containment Program, Technical Specification 5.5.2. Outboard gate valve bonnet and stem leakage identified during the system walkdown at pressures >1000 psig will be eliminated. The gate valves will be closed during this check. Gate valve seat water leakage measured at lt 1.1 P. will be limited by the Program, which restricts allowable i leakages to half of that assurned in the dose calculations (see Section 15.6.5.5.1.2.b).

This water leakage is not redundantly added into the Type C 0.60 L. totals, secondary containment

^ bypass airleakage totals or the hydrostatic test program totals. .^.n " -

. ;pnL .; _;;; tin tr= .t; tt Te Feedwater check valves (N27-F559 A/B and-B21-F032 A/B) utilize an altemate testing methodology 6;;';'n;; '?!re! hpe.!:r. c' t5c -

'/de: ::;;; per the Inservice Testing Program, to verify proper closure.

l Insert for NOTE 7 1

\

Note to reviewers:

i l

The following insert for NOTE 7 on page 6.2-250 is simply restoring the correct wording for this NOTE regarding closed systems outside containment. A change made in Revision 8 of the USAR had incorrectly revised NOTE 7 such that it became a specific 1

note forjust one type of penetration (the airlocks), versus the generic note that it had historically been. This is being corrected under the PNPP Corrective Action Program.

l The Insert to NOTE 7 therefore, is not a change being made as a result of the proposed feedwater penetration improvement amendment, per se, other than the addition of the l

reference to GDC 55.

...an isolation valve and a closed sy's tem outside containment which is in compliance  ;

with 10 CFR 50, Appendix A, GDC 54 and 55. A single active failure can be l l

accomodated. The closed system is missile protected, Seismic Category I, Safety Class 2, and has a temperature and pressure rating in excess of that for the containment. Closed system integrity is maintained and verified during periodic Type A test and during system leak tests (per NUREG-0737 ltem lli.D.1.1).

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Attachment 3 PY-CEl/NRR-2370L Page 8 of 11 PY.

2352L e sa o TABLE 6.9-1 '

SINGLE FAILURE ANALYSIS OF FEEDVATER LEAKAGE CONTROL SYST COMPONENT / EQUIPMENT HALFUNCTION CONSEQUENCES RHR vaterleg pump Either pump fails to $

LPCS vaterleg pump One subsystem is i operate inoperative. System requirements met by redundant pump and associated subsystem.

Motor operated valve on Either valve fails to One subsystem is either waterleg pump open inoperative.

discharge line System requirements met by

}; Jj g redundant subsystem.

Feedvater shutoff Feedvater shutoff valve valve e outboard subsystem fails to close as ciated with the i

i fail valve remains deacti ted by virtue of an in rlock signal from shuto valve position su h. The FVLC system requirements ar met by the redund. ant ,

nboard subsystem.

i 6.9-7 i

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N Attachment 3 PY-CEl/NRR-2370L Page 9 of 11 chme PY- RR-2352L ge 57 o Insert Page 6.9-7 Division 1 AC electrical Totalloss of both the power Division 3 electrical power normal and emergency is made available to the Division 1 AC electrical Feedwater system motor power sources.

operated gate valves by manual operator action per plant emergert:y procedure. The Division 2 FWLC subsystem is then utilized to provide the water seal on the MOV.

Insert to the "Feedwater shutoff valve malfunction" item The Feedwater Leakage Control System is vulnerable to this extremely unlikely event. However, the licensing basis for the Feedwater penetrations is that a water sealin the Feedwater piping outboard of the shutoff valves would remain for a sufficient length of time following the  ;

accident until the control l room operator successfully  ;

isolates the motor-operated '

valves. Therefore, these valves are assumed to work. Also, each ,

Feedwater line contains two l check valves which are i classified as containment  !

isolation valves on this '

penetration, and they provide a redundant

{

containment isolation I function. The proper closure of the check valves is verified 6; e "!r !

h:;:d!:r. prd^m: ' per  ;

the Inservice Testing '

Program.

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Ausdwnst 3 PY-CEl/NRR-2370L Page 10 of 11 p -2352L e e 73 of '

15.6.6.5.2.2 Fission Prcduct Transport to the Environment The transport pathway consists of liquid release from the break, carryover to the turbine building atmosphere due to flashing and unfiltered release to the environment through the turbine building j ventilation system.

The total integrated mass of coolant leaving the break is 1.454 E6 lbs of condensate. For.the purposes of this evaluation, the conservative.

assumption is made that the activity of iodine per pound of steam is equal to 2 percent of the activity per pound of water.

Taking no credit for holdup, decay or plateout during transport through l the turbine building, the release of activity to the environment is presented in Table 15.6-21.

The total release is assumed to take place within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the occurrence of the break.

15.6.6.5.2.3 Results l

The calculated exposures for the realistic analysis are presented in Table 15.6-22 and are a small fraction of 10 CFR 100 guidelines.

IT.6 k k 15.6.7 CES Foh NTST6 ~ ~

1. Hoody, F. J.,

" Maximum Two-Phase Vessel Blowdown From Pipes," ASME Paper Number 65-VA/HT-1, March 15, 1965.

2. USNRC Standard Review-Plan, NUREG-75/087.
3. Brutschy, F. J., G. R. Hills, N. R. Horton, A. J. Levine, " Behavior of Iodine in Reactor Vater Ducing Plant Shutdown and Startup,"

August 1972, (NED0-10585).

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15.6-32

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' Attachment 3 py.CEl/NRR-2370L Page 11 of11 P R-2352 74 Insert Page 15.6-32 15.6.6.5.2.4 SensitivityAnalysia As described in USAIR Section 6.2.4.2.2.1.a.1, should a break accur in a feedwater line, th control closure check valves prevent significant loss of reacto. .,oolant inventory and 5.rov immediate isolation. A sensitivity analysis was performed to estimate the amount ofle that would have to occur through the control closure check valves in order for the consequences of a feedwater line break outside containment event to exceed the consequences of the main steam line break outside containment. The results of the sensitivity analysis are that the leakage through the control closure check valves would have to exceed 200 gallons per minute for each feedwater line (400 gallons per minute total) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order for the consequences 95 the feedwater line break outside containment to R

exceed the consequences of the main steam line .c -

break

.g 3 outsid 10 Orn 50 A;;r-d'- J ': ;i:::' heWJer. of th; id;; ret frem u..fr a??S to reet'd'er). D* .f will verify proper closure of these valves to prevent significant leakage of this order of magnitude.

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