ML20216B940
| ML20216B940 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/15/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20216B904 | List: |
| References | |
| NUDOCS 9805190022 | |
| Download: ML20216B940 (14) | |
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UNITED STATES g
I NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C.
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 221 TO FACILITY OffL'_ TING LICENSE NO. NPF-3 TOLEDO EDISON COMPANY CENTERIOR SERVICE COMPANY 88Q THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION. UNIT NO. 1 DOCKET NO. 50-346
1.0 INTRODUCTION
By letter dated June 24, 1997, Toledo Edison Company, Centerior Service Company, and The Cleveland Electric Illuminating Company (the licensees),
submitted a request for changes to the Davis-Besse Nuclear Power Station, Unit No. 1. Technical Specifications (TSs).
The proposed amendment would change TS Section 3/4.3.2.1, " Safety Features Actuation System (SFAS) Instrumentation," TS Section 3/4.6.1.7, " Containment Ventilation System," TS Section 3/4.6.3.1, " Containment Isolation Valves," and TS Section 3/4.9.4 " Refueling Operations - Containment Penetrations," and the 3
associated TS Bases.
Valve position and control power requirements would be added, and certain containment radiation monitor requirements, valve isolation i
verification requirements, and containment radiation monitor optional uses would be deleted. Administrative changes would also be made.
2.0 BACKGROUND
Four SFAS area radiation monitors are located in the containment annulus during normal operations. These monitors are designed to withstand the containment environment in all modes, and send an isolation signal on high containment radiation. This signal will shut down the containment purge supply and exhaust fans, close the purge supply and exhaust valves, close the containment air sample isolation valves, open the bypass damper to the Emergency Ventilation System (EVS), and start the EVS.
Davis-Besse TS 3.6.1.7, " Containment Ventilation System," requires the containment purge supply and exhaust isolation valves normally to be closed in Modes 1, 2, 3 and 4.
However,_ this TS does allow these valves to be open for limited periods in these modes.
By letter dated June 24, 1988, the licensees committed to keep these valves closed with control power removed in 9805190022 990415 PDR ADOCK 05000346 P
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, Modes 1,. 2, 3 and 4, and comitted to verify that the valves are closed once per 31 days, consistent with NRC staff guidance stated in NUREG-0800,
" Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 1
Power Plants, LWR Edition" (SRP), Section 6.2.4.II.6.f, and in the NRC letter to the licensees dated February 16, 1983.
3.0 LICENSING BASIS In addition to the affected TSs, the licensing basis for the systems affected by the proposed changes includes:
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3.1 Licensees' letter to NRC dated December 30, 1982.
i This letter contains the licensees' interim comitment to keep the con-tainment purge supply and exhaust valves closed in Modes 1, 2, 3 anc 4.
3.2 NRC letter to licensees dated February 16, 1983.
This letter contained the staff's request for information to determine if the licensees intended to maintain the containment purge supply and exhaust valves closed and to verify valve closure every 31 days in V Wes 1, 2, 3 and 4, consistent with the staff position, until the licensees submitted acceptable information demonstrating valve operability.
3.3 Licensees' letter to NRC dated March 16, 1983.
This letter is the licensees' response to 3.2.
The licensees comitted to continue to maintain the containment purge supply and exhaust valves closed and to verify valve closure once per shift in Modes 1, 2, 3 and 4.
Note that the NRC position as stated in 3.2 was to verify valve closure once every 31 days.
3.4 Licensees' letter to NRC dated June 24, 1988.
In this letter, the licensees reaffirmed their comitment~ for valve closure as stated in 3.3, but changed their ve.rification comitment to once per 31 days (consistent with the NRC position) from once per shift.
3.5 Davis-Besse Updated Safety Analysis Report (USAR) Section 6.2.3,
" Containment Vessel Air Purification and Cleanup System," Section 7.3,
'" Safety Features Actuation System," Section 9.4, " Air Conditioning, Heating, Cooling, and Ventilation Systems," and Section 15.4, " Class 3 -
Design Basis Accidents," through Revision 20, December 1996.
The design and operation of the containment purge supply and exhaust system is described in USAR Section 6.2.3.
The licensees' comitments regarding valve closure and control power removal are discussed.
The licensees' comitment to keep these valves closed and depowered in Modes 1, 2, 3 and 4 is also stated in USAR Section 7.3.
, A functional drawing of the containment gas analyzing system and the containment atmosphere radiation monitoring systen; is provided in USAR Section 9.4, Figure 9.4-11A. This drawing shows that both systems are closed systems that draw samples from containment, process the samples, and return the samples back to containment.
The assumption that there is no containment isolation for a fuel handling accident inside containment (see Section 3.11 below) is stated in USAR Section 15.4.7.3.2.
That is, consistent with tre accident analyses, the containment purge supply and exhaust valves do not need to be closed in Modes 5 and 6, though radiation rnitors must be operable to alert operators of an accident so they ca olose the valves.
3.6 NUREG-0136, " Safety Evaluation Report Related to Operation cf Davis-Besse Nuclear Power Station, Unit 1" (SER), Section 6.2.4, December 1976.
Section 6.2.4 of the staff's SER discusses the Containment Isolation System. The SER states that containment isolation automatically occurs upon receipt of a containment high pressure signal or a reactor coolant system low pressure signal. High radiation signals are also used to isolate the containment vessel purge system lines.
3.7 NUREG-0737, " Clarification of TMI Action Plan Requirements,"
Section II.E.4.2, Positions 1 and 6, November 1980.
Position 1 states that there should be diversity in the parameters sensed for the initiation of containment isolation.
Position 6 states that containment purge valves that do not satisfy specific operability criteria must be sealed closed in Modes 1, 2, 3 and 4, with closure verified at least every 31 days.
3.8 SRP Section 6.2.4.11.6, Subsections 1 and m, and Branch Technical Position (BTP) CSB 6-4, June 1987.
Subsection 1 states that there should be diversity in the parameters l
sensed for the initiation of containment isolation to satisfy the requirement of General Design Criterion 54 for reliable isolation capability.
Subsection m states that system lines which provide an open path from the containment to the environs (such as the purge and vent lines) should be equipped with radiation monitors that can isolate these lines on a high radiation signal.
In addition, this section states that a high radiation signal should not be considered one of the diverse containment isolation parameters.
BTP CSB 6-4 states the design and operability criteria for the subject 3
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valves.
, 3.9
'av k-Besse TS Amendment No. 37 dated March 24, 1981.
The Safety Evaluation (SE) for this amendment states that the containment isolation diverse parameters are low reactor coolant system pressure and high containment pressure.
3.10 Davis-Besse TS Amendment No. 73 dated July 25, 1984.
The SE for this amendment closed Item II.E.4.2.6 of NUREG-0737 (see 3.7 above) related to containment purge valves. The licensees' commitments and potential future evaluations were discussed.
3.11 Davis-Besse TS Amendment No. 186 dated April 15, 1994.
This amendment approved use of the containment purge supply and exhaust system noble gas monitor as an alternative to the SFAS area radiation monitors, during operations such as core alterations or movement of irradiated fuel inside containment.
If there is a fuel handling accident during these operations, the noble gas monitor would send a high radiation signal to the control room, and would automatically contain any radioactive release in progress by stopping the containment purge system supply and exhaust fans and closing their inlet and outlet dampers.
The containment purge supply and exhaust isolation valves could then be closed by manual action in the control room.
4.0 EVALUATION The licensees are proposirig several TS changes, including valve position and coni.rol power requirements, that will allow removal of equipment, which, in turn, will eliminate the associated maintenance and surveillance testing requirement:.
Consistent'with these changes, some TS requirements will be deleted and nior TS requirements will be added to ensure that the containment purge supply -iid exhaut isolation valves are maintained in a safe condition consistent with NRC staff positions.
Each proposed change is evaluated below.
4.1 Table 3.3-3. " Safety Features Actuation System Instrumentation" (a)
Remove Line 1.a, Containment Radiation - High This TS lists operability requirements, applicable modes and required actions for the " Containment Radiation - High" instrument string. The
" Containment Radiation - High" signal is used to initiate actions for Incident-Level 1 of the SFAS Instrumentation. The EVS fans are started, HV (heating and ventilating) and AC (air conditioning) isolation valves are closed (including EVS, ECCS room, emergency ventilation, containment air sample, containment purge and penetration room purge valves), and the control room HV and AC air handling valves are closed.
The licensees are proposing to delete this line in its entirety.
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, EVS fans and valves. ECCS room v Qys.3. emeroency ventilation valves. and oenetration room ource valves:
In addii. ion to receiving an initiating signal on " Containment Radiation - High," these components receive initiation signals on high containment pressure and low reactor coolant i
system (RCS) pressure.
Since there are two additional initiating signals, and since none of the associated systems provides a direct path from the containment to the environs (see Section 3.8 above), the
" Containment Radiation - High" signal is not needed to provide diverse actuation of these systems.
Containment ource valves: As stated in Sections 3.4 and 3.5 above, the licensees have committed to keep these valves closed and depowered in Modes 1, 2, 3 and 4.
In addition, as discussed below, the licensees are proposing to modify TS 3.6.1.7 to provide requirements to ensure that these valves are closed and depowered.
Consistent with Sections 3.5 and 3.7 above, these valves do not need to be closed in Modes 5 and 6 provided, however, that the containment purge supply and exhaust system noble gas monitor is capable of providing a high radiation signal to the control room.
TS 3/4 9.4 is being changed (see below) to ensure this capability.
Therefore, the " Containment Radiation - High" signal is not needed to initiate closure.
I egetainment air samole valves:
In addition to closing on " Containment Radiation - High," the air sample valves close on high containment i
pressure and low RCS pressure.
If the air sanple lines provided a j
direct path from the containment to the environs (see Section 3.8
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above), the lines would need to be monitored for radiation, with automatic valve closure on a high radiation signal, unless the isolation valves were closed and depowered. However, as stated in Section 3.5 above, these lines are part of closed systems that recirculate 4
containment air, with no direct path to the environs. Therefore, radiation monitoring is not required.
Since the ramoval of the systems listed above from the list of SFAS actuated equipment for a Level 1 incident is acceptable, and since these are the only systems which are affected by the " Containment Radiation -
High" signal, the removal of Line 1.a, " Containment Radiation - High,"
from Table 3.3 3 is acceptable.
(b)
Remove "6****" knder " Applicable Modes" from Line 2.a, " Incident Level #1: Containment Isolation" This TS lists operability requirements, applicable modes and required actions for the " Incident Level #1:
Containment Isolation" output j
logic. The licensets are proposing to delete the requirement for this logic to be operable in Mode 6.
' Consistent with Sections 3.5 and 3.7 above, containment isolation through the SFAS systen is not required in Mode 6 provided that the containment purge supply and exhaust system noble gas monitor is capable j
4 t of providing a high radiation signal to the control room. TS 3/4 9.4 is being changed (see below) to ensure this capability.
i Since containment isolation through the SFAS system it not required in Mode 6, the proposed deletion is acceptable.
(c)
Remove "6****" under " Applicable Modes" from Line 3.a, " MANUAL ACTUATION - SFAS (except Containment Spray and Emergency Sump Recirculation)"
This TS lists operability requirements, applicable modes and required actions for SFAS manual actuation. The licensees are proposing to
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delete the requirement for this functional unit to be operable in i
Mode 6.
Only SFAS Incident Level #1, Containment Isolation, is factional in j
Mode 6.
Consistent with Sections 3.5 and 3.7 above, containment isolation through the SFAS system is not required in Mode 6 provided that the containment purge supply and exhaust system noble gas monitor is capable of providing a high radiation signal to the control rcom.
TS 3/4 9.4 is being changed (see below) to ensure this capabilitj Since SFAS Incident Level #1 is the only functional unit, and since containment isolation through the SFAS system is not required in Mode 6 i
subject to the stated conditions, the proposed deletion is acceptable.
(d)
Remove Table Notation "****"
This footnote discusses required instrumentation in Mode 6.
The licensees are proposing to delete this footnote.
Since all references to this footnote are being deleted (see a, b and c above), this in an administrative change only, and is therefore acceptable.
4.2 Table 3.3-4. " Safety Features Actuation System Instrumentation Trio Setooints" (a)
Remove Line (a), " INSTRUMENT STRINGS - Containment Radiation" This TS lists the trip setpoint and allowable values for the containment radiation instrument string. The licensees are proposing to delete this line.
Since the containment radiation instrument string is being deleted (see 4.1.a above), the deletion of this TS line is an administrative change only, consistent with the other changes, and is therefore acceptable.
4.3 Table 3.3-5. " Safety Features System Resoonse Times" (a)
Correct spelling of "RE[S)PONSE" in title This spelling error does not appear in the official NRC records.
It was generated by the licensees in their copies only.
Therefore, no change
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is necessary.
, (b)
Remove Line 1.b.4, "HV & AC Isolation Valves - Containment Purge" This TS lists the acceptable response time for manual SFAS actuation of containment purge. The licensees are proposing to delete this line.
Section 4.1.a above discusses the disposition of these valves.
Reiterating, the valves will be closed and depowered in Modes 1, 2, 3 and 4, and the containment purge supply and exhaust system noble gas monitor is capable of providing a high radiation signal to the control room in Modes 5 and 6 (allowing operators to manually close the valves if they are open). Therefore, response time restrictions on these valves are not necessary, and the proposed deletion is acceptable.
(c)
Remove Line 2.b.4, "HV & AC Isolation Valves - Containment Purge" This TS lists the acceptable response time for SFAS actuation of containment purge due to a " Containment Pressure - High" signal. The licensees are proposing to delete this line.
The disposition of these valves is discussed in 4.3.b above.
Since response time restrictions on these valves are not necessary, the proposed deletion is acceptable.
(d)
Remove Line 4.b.4, "HV & AC Isolation Valves - Containment Purge" This TS lists the acceptable response time for SFAS actuation of containment purge due to an "RCS Pressure - Low" signal. The licensees are proposing to delete this line.
The disposition of these valves is discussed in 4.3.b above.
Since response time restrictions on these valves are not necessary, the proposed deletion is acceptable.
(e)
Remove Line 6, " Containment Radiation - High," and all subheadings This TS lists the acceptable response times for SFAS actuation of emergency vent fans, HV & AC isolation valves, and control room HV & AC units due to a " Containment Radiation - High" signal. The licensees are proposing to delete this line and all subheadings.
Section 4.1.a above discusses the acceptability of the licensees' proposed removal of the " Containment Radiation - High" signal.
Since this signal is being removed, the proposed removal of Line 6 (and subheadings) is an administrative change consistent with the other changes, and is therefore acceptable.
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- j 4.4 Table 4.3-2. " Safety Features Actuation System Instrumentation Surveillance Reauirements" (a)
Remove Line 1.a, " INSTRUMENT STRINGS - Containment Radiation - High" This TS lists the surveillance requirements and applicable modes for the
" Containment Radiation - High" instrument string.
The licensees are proposing to delete this line.
Section 4.1.a above discusses the acceptability of the licensees' proposed removal of the " Containment Radiation - High" signal.
Since this signal is being removed, the proposed removal of Line 1.a is an administrative change consistent with the other changes, and is therefore acceptable.
(b)
Remove ",6f" under " MODES IN WHICH SURVEILLANCE REQUIRED" from Line 2.a,
" OUTPUT LOGIC - Incident Level f!: Containment Isolation" This TS states that surveillance testing is required for the Containment Isolation output logic in Mode 6.
Footnote # provides clarification that this requirement does not apply when the containment purge supply and exhaust system noble gas monitor is in service.
The licensees are I
proposing to delete this requirement.
Consistent with Sections 3.5 and 3.7 above, containment isolation through the SFAS system is not required in Mode 6 provided that the containment purge supply and exhaust system noble gas monitor is capable of providing a high radiation signal to the control room. TS 3/4 9.4 is i
being changed (see below) to ensure this capability.
Since containment isolation through the SFAS system will not be required in Mode 6, the proposed deletion is acceptable.
(c)
Remove ",6f" under " MODES IN WHICH SURVEILLANCE REQUIRED" from Line 3.a,
" MANUAL ACTUATION - SFAS (Except Containment Spray and Emergency Sump Recirculation)"
This TS states that surveillance testing is required for SFAS manual actuation (except containment spray and emergency sump recirculation) in Mode 6.
Footnote # provides clarification that this requirement does not apply when the. containment purge supply and exhaust system noble gas monitor is in service. The licensees are proposing to delete this requirement.
Consistent with Sections 3.5 and 3.7 above, containment isolation through the SFAS system is not required in Mode 6 provided that the containment purge supply and exhaust system noble gas monitor is capable of providing a high radiation signal to the control room.
TS 3/4 9.4 is being changed (see below) to ensure this capability.
In addition, no other SFAS incident levels are required while in Mode 6.
l l Since no SFAS incident levels will be required in Mode 6 after the i
proposed changes are in effect, the proposed deletion is acceptable.
(d)
Remove TABLE NOTATION "f" This footnote discusses required instrumentation in Mode 6.
The licensees are proposing to delete this footnote.
Since all references to this footnote are being deleted (see a, b and c above), this is an administrative change only, and is therefore acceptable.
4.5 TS 3.6.1.7. " CONTAINMENT SYSTEMS - CONTAINMENT VENTILATION SYSTEM -
LIMITING CONDITION FOR OPERATION (a)
Add "with control power removed" to the Limiting Condition for Operation (LCO)
This TS states that "The containment purge supply and exhaust valves shall be closed." The licensees are proposing to add the phrase "with control power removed."
4 This addition will codify into the TSs the commitment the licensees have made, as documented in the USAR (see Section 3.5).
This change provides additional assurance that the valves will not be inadvertently opened, and is a necessary condition for removal of the " Containment Radiation - High" instrument string (see Section 4.1.a).
Since this change provides additional assurance of safe operation, it is acceptable.
(b)
Modify the Lt0 action statement The current action statement reads:
With any containment purge supply and/or exhaust isolation valve open and providing access to the outside atmosphere, operation may continue, provided that the accumulated time is s 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> for the preceding 365 days; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
As stated in TS Bases 3/4.6.1.7, the 90-hour restriction over a one-year period is approximately equivalent to 1% of the total possible yearly unit operational time. This period was chosen to minimize the time that a direct open path would exist from containment to the outside atmosphere, reducing the probability that an accident dose would er.eed 10 CFR Part 100 values.
The licensees are proposing the following action statement to replace the current statement:
, With one isolation valve open in a containment purge supply and/or exhaust penetration, or with its control power not removed, verify that the remaining containment purge supply and exhaust isolation valves are closed with control power removed by performing Surveillance Requirement 4.6.1.7 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Close the open containment purge supply and/or exhaust isolation valve and verify control power is removed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in i
at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
This change reduces the time that one valve can be open at one time,
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ensures that the ether valves are closed, and eliminates the need for valve position trheking. This change is conservative, and provildes reasonable assurance that an accident would not exceed 10 CFR Part 100 values.
Therefore, this change is acceptable.
(c)
Modify the surveillance requirement (SR)
The current SR reads:
The accumulated time any containment purge supply and/or exhaust valve is open and provides access to the outside atmosphere shall be determined at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensees are proposing the following action statement to replace the current statement:
1 At least once per 31 days verify that each containment purge supply and exhaust isolation valve is closed with control power removed.
With the change in 4.5.b above, the current SR is no longer necessary.
The proposed SR is consistent with the current licensing basis, as discussed in Section 3.4.
Therefore, this change is acceptable.
4.6 TS 4.6.3.1.2. " CONTAINMENT SYSTEMS - CONTAINMENT ISOLATION VALVES -
SURVEILLANCE REQUIREMENTS" (a)
Delete SR 4.6.3.1.2.b This SR requires that each isolation valve shall be demonstrated 1
operable at least once each refueling interval by " Verifying that on a Containment Purge and Exhaust isolation test signal, each Purge and Exhaust automatic valve actuates to its isolation position." The licensees are proposing to delete this requirement.
With the proposed changes in this amendment request in place, these valves will no longer require automatic isolation.
Therefore, this SR is not necessary, and its removal is acceptable.
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. 4.7 TS 3/4.9.4. " REFUELING OPERATIONS - CONTAINMENT PENETRATIONS" (a)
Modify TS 3.9.4.c.2 This TS currently reads:
The containment penetrations shall be in the following status:
c.
Each penetration providing direct access from the containment atmosphere to the atmosphere outside containment shall be either:
1.
Closed by a manual or automatic isolation valve, blind flange, or equivalent, or i
j 2.
Be capable of being closed by an OPERABLE containment purge and exhaust isolation valve.
The licensees are proposing to modify this TS to read:
The containment penetrations shall be in the following status:
c.
Each penetration providing direct access from the containment atmosphere to the atmosphere outside containment shall be either:
1.
Closed by a manual or automatic isolation valve, blind flange, or equivalent, or 2.
Be capable of being closed from the control room by an OPERABLE containment purge and exhaust isolation valve upon receipt of a high radiation signal from the containment purge and exhaust system noble gas monitor.
The proposed TS ensures that the noble gas monitor will be available during refueling operations, which is a necessary condition for the proposed removal of the containment radiation monitors (see Section 4.1).
Since these changes ensure system availability, they are acceptable, j
(b)
Modify TS 3.9.4 Action (b)
This action currently reads:
With the containment purge and exhaust isolation system inoperable, close each of the purge and exhaust penetrations providing direct access from the containment atmosphere to the outside atmosphere.
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. The licensees are proposing to modify this action to read:
With the requirements of Specification 3.9.4.c not satisfied for the containment purge and exhaust system close at least one of the isolation valves for each of the purge and exhaust penetrations providing direct access from the containment atmosphere to the outside atmosphere within one hour.
The proposed changes add clarifying statements consistent with the proposed changes to TS 3.9.4, and add a time restriction to the action.
i Since these changes are conservative and consistent with the additions to TS 3.9.4.c.2, they are acceptable.
(c)
Delete a portion of TS 4.9.4.b j
This SR. currently reads:
b.
Verifying... the containment purge and exhaust isolation valves can be closed from the control room, or If using the SFAS area radiation monitors, verifying that on a Containment Purge and Exhaust Isolation test signal, each purge and exhaust isolation valve automatically actuates to its isolation position.
The licensees are proposing to delete the second paragraph, so that this SR would read:
b.
Verifying... the containment purge and exhaust isolation valves can be closed from the control room.
The proposed change removes the option to use the SFAS area radiation monitors during refueling operations.
Since the licensees are proposing to remove these monitors, this change is necessary, and is therefore acceptable.
4.8 TS BASES 3/4.6.1.7. " CONTAINMENT VENTILATION SYSTEM" (a)
Replace the bases The licensees are proposing to delete the exitsting bases, and replace it with:
Maintaining the containment purge supply and exhaust isolation valves closed with control power removed at all times during MODES 1, 2, 3 and 4 provides assurance that the safety function of containment isolation is maintained in the event of a LOCA.
I
e The ACTION statement assures that at least one containment purge supply and exhaust isolation valve is closed in each containment penetration and provides reasonable time to permit closure of an open valve.
The replacement text is consistent with the proposed TS changes, providing clarifying information. Therefore, this change is acceptable.
4.9 TS BASES 3/4.G.3. "CONTAINMENTj SOLATION VALVES" (a)
Add to the bases The licensees are proposing to add the following to the existing bases:
The containment purge supply and exhaust system isolation valves are considered OPERABLE with respect to containment isolation when they meet the requirements of Specification 3.6.1.7.
This proposed addition adds clarifying information consistent with the other changes proposed by the licensees. Therefore, this addition is acceptable.
4.10 TS BASES 3/4.9.4. " CONTAINMENT PENETRATIONS" (a)
Delete one paragraph from the Bases The licensees are proposing to delete the last paragraph of this section of the existing bases:
Likewise, use of the SFAS area radiation monitors provide (sic) an automatic containment isolation signal on high radiation, restricting the uncontrolled release of radioactive material from the containment to the environment.
This deletion is consistent with the removal of the SFAS area radiation monitors, and is therefore acceptable.
j (b)
Add two paragraphs to the Bases The licensees are proposing to add the following:
With the containment purge and exhaust system nu *-
l operation, there would be no flow to the containment purge: and exhaust system noble gas monitor, hence the requirements of Specification 3.9.4.c.2 would not be satisfied.
In this
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situation, unless Specification 3.9.4.c.1 is satisfied, entry into the Action statement would be required.
i With a containment purge penetration not capable of being closed from the control room by an OPERABLE containment purge and exhaust isolation valve upon receipt of a high radiation signal
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- u from the containment purge and exhaust system noble gas monitor, closure of the containment purge and exhaust penetrations with at least one isolation valve ensures that the uncontrolled release of radioactive material from the containr ent to the environment will be restricted.
These additions add clarifying statements consistent with the proposed TS changes. Therefore, they are acceptable.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment. The State official had no t
comments.
6.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to ir.stallation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes a surveillance requirement.
The staff has determined that j
the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (62 FR 40858). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) s9ch activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
A. Hansen Date: April 15, 1998 I