ML20217B787
| ML20217B787 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 03/20/1998 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20217B772 | List: |
| References | |
| NUDOCS 9803260176 | |
| Download: ML20217B787 (454) | |
Text
{{#Wiki_filter:l j McGuire & Catawba Improved TS Review Comments l ,. ITS Section J.6, Containment Systems
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D 3.6.1 Containment 3.6.1 -1 DOC A.3 (McGuire Only) DOC A.33 CTS 3.6.1.1 ACTION CTS 3.6.1.1 requires Containment Integrity be maintained. ITS LCO 3.6.1 changes Containment integrity be maintained to containment shall be OPERABLE. This change is designated DOC A.3 throughout the CTS markup of ITS 3.6.1. However, this change made to CTS 3.6.1.1 ACTION for McGuire Unit 1 is designated DOC A.33 while for Unit 2 and Catawba the change is designated DOC A.3. DOC A.33 is listed in the Justifications as "Not Used." Comment: Correct this discrepancy in the McGuire Unit 1 CTS markup. DEC Response: The CTS Markup for McGuire unit 1 has been corrected. O I I l mc3_cr_3.6 3.6-1 March 12, 1998 9003260176 900320 PDR ADOCK 05000369 P PDR
Specificaite'n g. 4,, j
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8 CONTAIMENT SYSTEMS . _ $8.1 @ CONTAIMENT . M INTp6RITC 6furtINE MITIONFBIOPER613b QJ.1.f pr*4 CONTAlmDfTM shall be@ta)6ejdradih kl , APPLICABILITY: WJDES 1, 2, 3 and 4 h* gt Wootw % l ElllE
/)ctjo A Iff ~
@ 6acAs%92 L
. g 3 1 hour er CONTA!M0(TQNf6ditNrestore CONTAlWD(TQlff thin SinI1Dolet within a attheleast HDT 30 following sianusf hours.within the next 6 hours and in COLO
$lktvEIL b AbMJI
!.6.1 4 Pri ry CO AI ranfTY/alu11 ddemondraM At least once per 31 days by verifying that all . penetrations
- not -
capable of being closed by OPDIABLE containment automatic isolation i ' gg go A or valves er operator action during periods when containment isolation T valves are open under administrative control." and required to be
/TS 5.(,.3 i
\ closed durias accideat coaditions are closed by v bifed tilanws. er deactivatad automatie valves secured in the l
f$tfah,$fae$ AQ C After e clost f each ration subj to Type testing k'excep at air l O -
'y fying dded to conta tes by leak te testi
'when the leakage r s, if seal wf sured tea followi as at p Type A
.8 psi rate for., se seal s nd B tp eieterni rsuant t on LA j4.6.1.2d or all et 8 and penetrati iff
, the cop 6fned 1
geaka te is les 0.60 L,. f r -
*Except valves, blind flanges, and deactivated automatic valves dich are]
- located inside the containment and the annulus and are locked, sealed or etherwise secured in the closed position. These penetrations shall be verified closed during each COLD $HilTDolci except that such vedfication need not be perfetued more eften than once per g2 days.
"The following valves may be opened on an interwittent basis under adminis-tretive centre 1: NC-141. IIC-142, idE-13, ifE-23, VX-34. VX-40, FW-11, FW-13, FW-4.
l ***A time chan it granted have the con i e est isolat valves for the upper and ament purge s ly and/or i 4 fell r compartae open in i 3 og the ste generator rept asent outage. The cumulati
/).l me for hay the vsive open in Modes and 4 is limi
- 14) days. I ether p visions of thi specification to fourte exception ly with these con ineent purge v ves open in des 3 and 4.
mvalve wil be sealed /losed prior to nitial entry to Mode 2. achf' J McGUIRE - UNIT 1 3/4 6-1 Amendment No.174 SV$ lC fO l
1 l l McGuire & Catawba Improved TS Review Comments f ITS Section 3.6, Containment Systems 3.6.1 -2 DOC A.3 ! DOC LA.1 JFD 6 l JFD Bases 6 CTS 4.6.1.1.c CTS 3.6.1.2.a, b, and c CTS 4.6.1.2.d CTS 4.6.1.2.d. 3) CTS 4.6.1.2.e, h, and i CTS 4.6.1.6 l STS SR 3.6.1.1 ITS SR 3.6.1.1 i ITS B3.6.1 Bases CTS 4.6.1.1.c, 3.6.1.2, 3.6.1.2 ACTIONS,4.6.1.2 and 4.6.1.2c, d, e, f, g, h and i specify various leak rate testing requirements and criteria for containment. CTS 4.6.1.6 specifies visual examinations to be performed on the containment vessel. STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to TSTF 52. The STS is based on 10 CFR 50 Appendix J Option A while the ITS is based on 10 CFR 50 Appendix J Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher 1. Grimes to Mr. David J. Modeen, NEl dated 11/2/95 and TSTF 52 as modified by staff comments. The ITS changes I
) are not in conformance with the letter and TSTF 52 as modified by staff comments. In ,
particular, Amendments 173 and 155 for McGuire Units 1 and 2 respectively and Amendments ' 144 and 138 for Catawba Units 1 and 2 respectively only approved 10 CFR 50 Appendix J ! Option for the Type A tests only. The Type B and C tests must still be done in accordance with Option A. Thus, only those leakage tests associated with Option B Type A test may be relocated to the Containment Leakage Rate Testing Program. This includes CTS 3.6.1.2.a. ! CTS 3.6.1.2 ACTION a, 4.6.1.2,4.6.1.2.c and 4.6.1.2.1 with regards to Type A tests only. All other CTS requirements specified above including CTS 4.6.1.2.i must be retained in the ITS as SRs or Notes to the SRs. Comment: Licensee to update submittal with regards to 11/2/95
- letter, TSTF 52 as modified by staff comments and the above comments or provide additional justification for deviations.
DEC Response: l CTS 4.6.1.1.c is redundant to the requirements in 10 CFR 50, Appendix J, Option A, Ill.D.2. l DOC L.33 is added to justify the deletion of this detail. ITS SR 3.6.1.1 is revised to address i Type A testing and inspections and new ITS SR 3.6.1.2 is added to capture the Type B and C l testing consistent with CTS 3.6.1.2.b,4.6.1.2.d 4.6.1.2.d.2 (McGuire),4.6.1.2.d.3 (Catawba), 4.6.1.2.d.4 (McGuire), 4.6.1.2.h, 4.6.1.2.1 (Catawba), and 4.6.1.2.J (McGuire). CTS 4.6.1.2.1 for McGuire is relocated to the Bases. CTS 4.6.1.2, 4.6.1.2.c, and 4.6.1.6 are part of the scope of the Type A testing performed pursuant to Option B and are not changed. Discussion of Changes A.3 and LA.1 have been revised accordingly. ITS 5.5.2 is also revised to match, mc3_cr_3.6 3.6-2 March 12, 1998
Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Vys cu.r Qgg SR 3.6.1.1 Perform required visual examinations andl In accordance l 1eakage rate testing except for containment with the air lock testing, in accordance with the l Containment Containment Leakage Rate Testing Program. Leakage Rate Testing Program l O I 1 O McGuire Unit 1 3.6-2 6/// f L t/20/97
]
INSERT 1 _____________.-------_-------------NOTE-----------------------------_-_- l The space between each dual ply bellows assembly on penetrations between the containment building and annulus shall be vented to the annulus during Type A tests. l INSERT 2 SR 3.6.1.2 -------------------NOTE--------------------
- 1. Following each Type A test, the space between each dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig to verify no detectable leakage, or the assembly shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa-
- 2. Type C tests on penetrations M372 and M373 may be performed without draining the glycol-water mixture from the seats -----NOTE------
of their diaphragm valves if meeting a SR 3.0.2 is not zero indicated leakage rate (not applicable including instrument error). --------------- Perform required Type B and C leakage rate In accordance testing, except for containment air lock with 10 CFR 50, testing and valves with resilient seals, in Appendix J, accordance with 10 CFR 50, Appendix J. Option A, as Option A, as modified by approved modified by exemptions. approved exemptions l O I l
Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY (/monti SR 3.6.1.1 UT $A Perfonn required visual examinations andA, In accordance l 1eakage rate testing except for containment with the air lock testing, in accordance with the Containment Containment Leakage Rate Testing Program. Leakage Rate l gg7 Testing Program A ' l l O l l l l l l l i I O . McGuire Unit 2 3.6-2 b// EfttT/97~
i INSERT 1 O() _______________.-------------------NOTE-------------_-_----_.--___--_--- The space between each dual ply bellows assembly on penetrations between the containment building and annulus shall be vented to the annulus during Type A tests. l _______________________ .... ___________________________________________ l l INSERT 2 SR 3.6.1.2 -------------------NOTE-------------___-_ -
- 1. Following each Type A test, the space between each dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig to verify no i detectable leakage, or the assembly l shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa-
- 2. Type C tests on penetrations M372 and M373 may be performed without draining ;
the glycol-water mixture from the seats -----NOTE------ j of their diaphragm valves if meeting a SR 3.0.2 is not zero indicated leakage rate (not applicable including instrument error). --------------- Perform required Type B and C leakage rate In accordance testing, except for containment air lock with 10 CFR 50, testing and valves with resilient seals, in Appendix J, accordance with 10 CFR 50, Appendix J, Option A, as Option A, as modified by approved modified by exemptions. approved exemptions O
Containment B 3.6.1 BASES APPLICABLE criteria imposed on all containment leakage rate testing. SAFETY ANALYSES L' =is14.8 assumed to be 0.3% per day in the safety rate analysis (continued) P psig (Ref. 3). Satisfactory leakage test at results are a requirement for the establishment of containment OPERABILITY. l The containment satisfies Criterion 3 of 10 CFR 50.36 l (Ref. 4). l l LCO - Containment OPERABILITY is maintained by limiting leakage to s1 IO NMEk b a re.0 auiLedanntainurni
, except priori aga to the first startupFrtwrmm waraAesting after performing leakage 1
l ' At this tighe gliced !4akage Mmin musgDg>
*\N-ma @ test.
Compliance with this LC0 will ensure a containment be'oN,O configuration, including equipment hatches, that is ! -N o d 'Tyrc.A structurally sound and that will limit leakage to those g Ak leakage rates assumed in the safety analysis. C O 'N - Individual leaka lock (LC0 3.6.2)ge ratesvalves specified V , purge with for the containment resilient seals, and air reactor building bypass leakage (LC0 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these
- individual limits only result in the containment being l inoperable when the leakage results in exceeding the overall i
acceptance criteria of 1.0 L,. i APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of l radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced t due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment
- during MODE 6 are addressed in LC0 3.9.4, " Containment Penetrations."
l I (continued) McGuire Unit 1 B 3.6-3 JgW 7 5/20/9P' t
l l Containment l B 3.6.1 (~ l ( BASES (continued) ACTIONS Al In the event containment is inoperable, containment must be i restored to OPERABLE status within 1 hour. The I hour Completion Time provides a period of time to correct the i i problem coninensurate with the importance of maintaining l containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. 161 and B.2 l If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a l MODr. in which the LC0 does not apply. To achieve this ; status, the plant must be brought to at least MODE 3 within l 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.1.1 i REQUIREMENTS 3P4 b l Maintaining the containment OPERABLE requires compliance j with the visual examinations andileakage rate test requirements of the Containment Leakage Rate Testing Program. Failure to meet specific leakage limits for the air lock, secondary containment bypass leakage path, and purge valve with resilient seals (as specified in LC0 3.6.2 l and LC0 3.6.3) does not invalidate the acceptability of the ! overall containment leakage detenninations unless the specific leakage contribution to overall Type A, B, and/or C 4 leakage causes one of these overall leakage limits to be exceeded. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to bee
~
La for c bine pype 6 an ic1g^fcligaang an outag sh"+ dn + l (included _ np R and C +ae ==1" -"
.75 L, for overall Type A leakage following an outage or shutdown that included Type A testing. At all other times between required leakage (continued)
McGuire Unit 1 B 3.6-4 $v p f L.5/20/9F l
Containment B 3.6.1 O' BASES SURVEILLANCE SR 3.6.1.1 (continued) REQUIREMENTS rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L . At s 1.0 L, the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis. REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Chapter 15.
- 3. UFSAR, Section 6.2.
- 4. 10 CFR 50.36, Technical Specifications, (c)(2)(11).
O O McGuire Unit 1 B 3.6-5 53pd b 5/M/97-
INSERT i n i (*) The Surveillance is modified by a Note which requires that the space between I i l each dual-ply bellows assembly on containment penetrations between the i containment building and the annulus be vented to the annulus during each Type i A test. I I I SR 3.6.1.2 : I l Maintaining the Containment OPERABLE requires compliance with the Type B and C l l 1eakage rate test requirements of 10 CFR 50, Appendix J. Option A (Ref.1), as i modified by approved exemptions. Failure to meet specific leakage limits for i the air lock, secondary conthinment bypass leakage path, and purge valve with i ! resilient seals as specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate l I the acceptability of the overall containment leakage determinations unless the i specific leakage contribution to Type A, B and/or C leakage causes one of I these overall leakage limits to be exceeded. As left leakage prior to the I first startup after performing a required 10 CFR 50, Appendix J, Option A, I leakage test is required to be < 0.6 L, for combined Type B and C leakage. At I all other times between required leakage rate tests, the acceptance criteria i l is based on an overall Type A leakage limit of s 1.0 L,. At s 1.0 L the i offsite dose consequences are bounded by the assumptions of the safe,ty I analysis. SR Frequencies are as required by Appendix J, Option A, as modified I by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) l l does not apply. These periodic testing requirements verify that the I l O)V containment leakage rate does not exceed the leakage rate assumed in the safety analysis, t i l The Surveillance is modified by a two Notes. Note 1 requires that following i I each Type A test, the space between each dual-ply bellows assembly be i subjected to a low pressure leak test with no detectable leakage. Otherwise, I the asumbly must be tested with the containment side of the bellows assembly I pressurized to P, and meet the requirements of SR 3.6.3.8. Note 2 allows l penetrations M372 and M373 to be tested without draining the glycol-water l l mixture from the associated diaphragm valves (NF-228A, NF-2338, and NF-234A) I as long as no leakage is indicated. This test may be used in lieu of Section I ! III.C.2(a) of 10 CFR 50, Appendix J, Option A which requires air or nitrogen I as the test medium. The required test pressure and interval are not changed. i I l All test leakage rates shall be calculated using observed data converted to i
- absolute values. Error analysis shall also be performed to select a balanced i integrated leakage measurement system. I l
INSERT Page B 3.6-5 O () McGuire 1
Containment , B 3.6.1 BASES APPLICABLE criteria imposed on all containment leakage rate testing. SAFETY ANALYSES L" =is14.8 assumed to be 3). 0.3% per day in the safety rate analysis test at I (continued) P, psig (Ref. Satisfactory leakage results are a requirement for the establishment of l containment OPERABILITY. l The containment satisfies Criterion 3 of 10 CFR 50.36 (Ref.4). l LCO Containment OPERABILITY is maintained by limiting leakage to s 1.0 L., except prior to the first startuo after performing j tr4.su, Apj ;v')J a reauirecre-m Lege niem=+4nn proorAleakage J test. At this timyhe (ppgacie learaae limits nyttD C.442 T5 pe 6)
- A C. \ta b7Md Compliance with this LC0 will ensure a containment be.<.o.4Lq m a. configuration, including equipment hatches, that is
&c.wlt Tp A structurally sound and that will limit leakage to those q pg leakage rates assumed in the safety analysis.
O <-o. I r k ,
) Individual leakage rates specified for the containment air lock (LCO 3.6.2), purge valves with resilient seals, and i
l reactor building bypass leakage (LC0 3.6.3) are not ' specifically part of the acceptance criteria of 10 CFR 50, i Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being . inoperable when the leakage results in exceeding the overall l acceptance criteria of 1.0 L,. I APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of I radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.4, " Containment Penetrations." l (continued) McGuire Unit 2 B 3.6-3 Isphtb/20/97- 5
( Containment B 3.6.1 i f l V' BASES (continued) ! ACTIONS L1 i In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The I hour Completion Time provides a period of time to correct the t problem connensurate with the importance of maintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time i period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. i ll B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full
- power conditions in an orderly manner and without l
challenging plant systems. i SURVEILLANCE SR 3.6.1.1 REQUIREMENTS , 3 Maintaining the containment OPERA Eirequires compliance I with the visual examinations and eakage rate test requirements of the Containment eakage Rate Testing Program. Failure to meet specific leakage limits for the l air lock, secondary containment bypass leakage path, and ' purge valve with resilient seals (as specified in LCO 3.6.2 and LCO 3.6.3) does not invalidate the acceptability of the overall containment leakage deteminations unless the specific leakage contribution to overall Type A, B, and/or C leakage causes one of these overall leakage limits to be exceeded. As left leakage prior to the first startup after perfoming a required Containment Leakage Rate Testing l Procram leakana test is required tgs La for comb 4 l ype B a eakage follo an outage shut down a , nelude vnaR*adCtae+p;elyrd _ 0.75 L, for overall Type leakage following an outage or shutdown that included Type A testing. At all other times between required leakage (continued) ( l McGuire Unit 2 B 3.6-4 5qp b dL M
Containment B 3.6.1 ( ' BASES SURVEILLANCE SR 3.6.1.1 (continued) , REQUIREMENTS rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L,. At s 1.0 La the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by the J Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis. ' IMEL
- REFERENCES 1. 10 CFR 50, Appendix J.
l l 2. UFSAR, Chapter 15. ! 3. UFSAR, Section 6.2.
- 4. 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
I O i l l C\ U McGuire Unit 2 8 3.6-5 EVP(MY DM
r INSERT I A I The Surveillance is modified by a Note which requires that the space between l each dual-ply bellows assembly on containment penetrations between the 1 l containment building and the annulus be vented to the annulus during each Type i ! A test. 1 I I SR 3.6.1.2 i i , Maintaining the Containment OPERABLE requires compliance with the Type B and C i l 1eakage rate test requirements of 10 CFR 50, Appendix J Option A (Ref. 1), as I modified by approved exemptions. Failure to meet specific leakage limits for i l the air lock, secondary containment bypass leakage path, and purge valve with i l resilient seals as specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate i ! the acceptability of the overall containment leakage determinations unless the i , specific leakage contribution to Type A, B and/or C leakage causes one of I i these overall leakage limits to be exceeded. As left leakage prior to the I i first startup after performing a required 10 CFR 50, Appendix J Option A, I leakage test is required to be < 0.6 L for combined Type B and C leakage. At I all other times between required leaka,ge rate tests, the acceptance criteria i is based on an overall Type A leakage limit of s 1.0 L . At s 1.0 L the i offsite dose consequences are bounded by the assumptio,ns of the safe,ty I i analysis. SR Frequencies are as requiret by Appendix J, Option A, as modified i by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) I does not apply. These periodic testing requirements verify that the i O C/ containment leakage rate does not exceed the leakage rate assumed in the safety analysis, i i The Surveillance is modified by a two Notes. Note 1 requires that following I l each Type A test, the space between each dual-ply bellows assembly be i subjected to a low pressure leak test with no detectable leakage. Otherwise, I l the assembly must be tested with the containment side of the bellows assembly l l pressurized to P, and meet the requirements of SR 3.6.3.8. Note 2 allows i l penetrations M372 and M373 to be tested without draining the glycol-water l l mixture from the associated diaphragm valves (NF-228A, NF-233B, and NF-234A) I as long as no leakage is indicated. This test may be used in lieu of Section i III.C.2(a) of 10 CFR 50, Appendix J, Option A which requires air or nitrogen i as the test medium. The required test pressure and interval are not changed. t l 1 All test leakage rates shall be calculated using observed data converted to i absolute values. Error analysis shall also be performed to select a balanced i integrated leakage measurement system. l l I INSERT Page B 3.6-5 McGuire l
1 Speci6caUen g,6,j 6 CONTAlmENT SYSTEMS .
$6.1JaH(ARIACONTAINNENT (ClEMilelElfT INTEdRITD dIIHTING COE6TTION FBI OPEREit3D 3 -
(34.1.f Prmar7 CONTAlfftENT8E4@ shall be(agtfitage)M b,j - APPLICABILITY: LODE 3 1, 2, 3, and 4 f E110ll: g (ivMa%923 o ostfattr & jjeffusA Wit g CONTAllelENTQNfEdhNrettore CONTAlfetENTthin g M 1 hour or 3NJ1Dowl within a at the least NOT 30 following auulosi hours.within the next 6 hours n COLD ' SI[RVEftd NCE lb tifRE b
/.6.1.[Pri ry Unr!Alb itsarry/shalt dtsM 4
At least once per 31 days by verifylag that all, penetrations
- not '.
capable of being closed by OPERABLE containment automatic isolation g g u of valves or operator action during periods when containment isolation T valves are open under adstnistrative control,** and required to be
\We'5 closed'" during accident coaditions are closed by valves, blind /TS 3.6 3 ) _.
d**ct ***d ""**"' '*1 5'*"r'd '" th*i r 5 8 t i'"5 :
'$' c Arter e k .? $ "* '
A,2 closta f each ration subj excep to Type testing ( - C(S fying 'v tes by leak conta te testing at air s, if open followin seal wi as at p Type A
.8 psig, ad 8 ,
8 dded to iwhen the suced leaka rate for., se seal is leakage ra deterni 4.6.1.2d or all o rsuant t pecific on / Type B and penetrati , the cog 51aed lQeaka ate is less 0.60 L,. f -
- *Except valves, blind flanges, and deactivated automatic valve otherwise secured in the closed position. These penetrations shall be
( f need not be performed more often than once per 92 days.verifled cl
**The trative following controla valves may be opened on as fatermittent basis under admints- J FW-4. NC-141,10C-142, WC-13. WE-23 VI-34, VK-40 FW-11 FW- -
***A . time cha is granted have the con ament purge s ly and/or e est isolat valves for the upper and 3 ed 4 fo11 ng the ste r compartae open in Mod
/),f ne for hay generator rept ement outage. The cumulati e
- 14) days. the valve open la Modes and 4 is lisi d to fourte exception 1 other pr visions of thi speelfication pply with -
those con ineent purge v ves open in
._ valve wil be sealed losed prior to nitial entry todes 3 and 4.
Mode 2. ach McGUIRE - UNIT 1 3/4 6-1 Amendment No.174 W lL 0 ge /of &
I l f ' Specification 3.6. l l INSERT la 43 SR 3.6.1.1 -------------------NOTE------------------- The space between each dual ply bellows assembly on penetrations between the containment building and annulus shall be vented to the annulus during Type A tests. In accordance Perform required visual examinations and with the Type A leakage rate testing in accordance Containment with the Containment Leakage Rate Testing Leakage Rate Program. Testing Program SR 3. 6.1. 2 -
----------------NOTE--------------------
- 1. Following each Type A test, the space between each dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig to verify no C detectable leakage, or the assembly shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa.
- 2. Type C tests on penetrations M372 and M373 may be performed without draining -----NOTE------
the glycol-water mixture from the seats SR 3.0.2 is not of their diaphragm valves if meeting a applicable zero indicated leakage rate (not --------------- including instrument error). In accordance Perform required Type B and C leakage rate with 10 CFR 50, testing, except for containment air lock Appendix J, testing and valves with resilient seals, in Option A, as accordance with 10 CFR 50, Appendix J, modified by Optton A, as modified by approved approved exemptions. exemptions A Q McGuire I Page A of G
Speeo.0CA!!*n ?.fo./ ICONfd M SY-Alas f rar jr lITisitlIT , F OPr ION C44.1.f/Contapdat 14adge rat /s shdbe M fa._ See Nddy An overall integrated leakage rate of less than er equal to L , j73 g,g;g 0.305 14.8 psig,. by weight of the containment air per 24 hours at P , b.
< 5 p 3 .(,,1.'.). A cea6ined leakage rate of less than 0.60 L for all penetrations andvalvessubjecttoType8andCtests,w$enpressurizedtoP.,;
and. . gei, p ,g Y af c. A combined bypass leakage rate of less than 0.07 L for all penetra-IN I'3'D tions identifiedto asP,. secondary containment bypass leakage paths when pressurized f APptICARILITY: MODES 1, 2, 3, and
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gg 4 4,,(,,,wf] [
, o . me n,sa u* & usar. 4 -
3e Agehe of _ erss.s/ Se-g3a, 95tii(a) M5L g yes. the asasan overall letterated containment leaka0e m or(b) the measurea =*tned leakage rate for all penetrations and? seh m.6 ypass ubject ta Twn*< a mad f ***** aw"iaa 8 88 L_ ar4c) sne -- M ed)
.----- rate ganeatn9 0.07 Lg -.m..___
h%N' h -y w
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we t 'E Tyne a Y C b in Y. == c E one noe weass eaaaoe rate w ins e ; tnan u n7 ggporo. --n=r
, *j* * % ,,r -- ' ^ L. -
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^
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. . sur a p gg , ,,o g , , g,p ,,,,, g sunwrittAncr ar0ufarMENTs ## '" 8' *3 See Airst 14.1.2 10 CFR 50.54 Type A containment leakage rates shall be demonstrated as
/T5 f,f,; exemptions, a(o) and Appendix J of 10 CFR 50, Option 8, as modified by approved gtember,1995.nd in accordance with the guidelines of Regulatory Guide
.' b *A ane- se change is gr ted to have exh contaisument purg upply and/or 3 4t isolation followingval i ssteam for the upper ad lower coupa generator at open in Mod r having the va s open in Mode lacement outa .
The cumulativ time 4./ and 4 is limi to fourteen i days. All other revisions of t s specification of those coat ly with the ex(! tion at purge valv open in Modes 3 4. Each val will be sealed clos prior to initial entry into Mode 2 McGUIRE - UNIT 1 3/4 6-2 Amendment No.174 i ye 3 o.f (o
St *CiEtN$10 ?,f, /
. , CONT T$ TEMS S EIL ~
REOUIREM S (Co inuedi Deleted
- l L 0 ele
- c. l dA*/ The accuracy of each Type A test shall be verified by a supplementail test in accordance with Regulatory Guide 1.163, September,19 d.
- Type B and C tests shall be conducted, in accordance with 10 CFR 50.54(o) and 10 CFR 50 Appendix J, tion A, with gas at P ,
14.8 (g, at intervals no gewater invol ag an 24 months except for tests sp g.L.b1 ' t QLfr)dcED the th anF () nd epaust isolp(ton valve /6 with resflient) N.m lu 4) Ct ts rforme on containee 5s.3.c.p). out rainNg the g1 col-water penetrat s M372, p their aphrage val s NF-228A, re f 2338, a theseats4f t g 7-meeti a zero ind ted leakage F-234A) f LA* te (not i ciuding trument. _ error far the di hrage valves.g These te any be 11 f tests wh are otnennye required eo in ' Secti
.2(a) of I CFR50,AppenpxJtoes air or a regenasj O
4 McGUIRE - (MIT 1 . 3/4 6-3 Amendment No.173
$$ h
I
$~pe.bstlth3.&,/
CONTMfhENTS TEMS a.i l VOL E RE REM (Conti ed) e
- t e fon j 1 g,g e. Pu e ly and e sea ska 1 be t est isolation alves with res lent mate al o Specificati ed and demons ated OPERABLE the requi nts 4.6.1.9.3 or .6.1.9.4, as ap icable; see NeA- (f.Thecombinedb ..
s ss leakage rate shall be determined to be less thaD i
# /753./, 3 - o.o7o t by appMable Type 8 and q tests at least once per '
l except for penetrations which are not individually testable; f
'. i no detectable Q is pressu leaka e when tested with soap bubble j
zed to P.,14.8 psig during each Type A test; l be tf 1 4 i E The spa between each dual-ply bell , m,q,g,g assembly on containment
>enet
>e tions between the contai building and the annulus sha
[ g nted to the annulus durina A tests. rFollowin compie oveach Ty>e a test, the spac tween eacn cual-ply be lows ssembly siall be subjected l A. verifr a' det'et*61' 1** a low ressure test at 3-5 g to
*r the dpressure
*1-Pir bella"5 *55 y Sh*11 be subjected to side of the dual-ply a leak e st with the on the co afnnent l 0 lows assembly at P,
,g,s leakage to be withi 14.8 Ifmits of Specif( tion 4. psi to verify the l 1.2f.:
(. All test leaka [&. . converted to rates shall be calculated usin observed data solute values. Error analyses h&1l be' performed to c elect a ba need Integrated teakage Measu nt System; and J. gee # pry $ r as s.s. The provision U Specification 4.o.2 are not applicabl ! /veh,b s n.1.c.i.t - , l l McGUIRE - UNIT 1 3/4 6-4 Amendment No.173 j?Gje Soh h
C & c25b 3.6/
~
conTAlisetT s O. ~
^ > == ' ystets -
~
[fiflis 'maIIfdif FOR CattiTIM 3.5.1@ primary CollTAIISIENT INTEGRITY shall be malatained. AppLICABILivY: fl00ES 1, 2, 3, and 4 6 , D/ KIL8: AdgM A trithernesadru?CollTAtleIDIT
& 43 ##$W restore CollTAlleIDIT thin ACh0/88 1 hear or be fii at least MOT $
SHinDolet within the followfag 30 hours.within the next 5 hours
~
a COLD f$ultyr/LUWCE a8 8fRDb { 14[1.1 prids UmMd;ruitmaITYjha11 he dyaliastratM l At least once per 31 days verifying that all
~
capable of being closed 6y ~etratfon. not, contafament i
.See //sef'Lo o valves are open under administrative control,** an !
gig closed during accident conditions are closed by vah es, blir d Qanges, or deactivated automatic valves secured in tyhe ssitions; hfyt amentfr locyis 1y'coip11phce
- c. Arter ; -= clost except conta of e genet 10a's ject testi test, y leak r tecks if fel owl Type or 3 tes og the I wi p .
O i veri gas psi og the esass for., and leaka ra ; to the eakage stes twined rs sea is 4 .1.2d. f .all o rT to iff ion akage ra S and C t toes, is 1 feed than 60 (. t ['*rW valves, blind flanges, and deactivated automa otherwise secured la the closed positten. These penetrations shall be need not be performed more often than once per 92 days.
**The followlag valves may be en am latersiitteet basis mader admints-trajivecentrola NC 141, IIC. 42, E13, 523, VX-34, VX-40, FW.11, FW.13,
***A ene-tise is granted to "I the containment exhaust fse ties valves for the supply and/or 3 and 4 f owfag the steam r and lower coupa t open in Mode time for ving the valves rater replacement .
The cumulativ
/)./ (14) . All other prov la Modes 3 and 4 is sited to fourtee ons of this specifica on apply with e ima of those contal t purge valves open Modes 3 and 4.
va e will be sealed c1 ed prior to initial en ch into Mode 2. McGUIRE . Ull!T 2 3/4 6-1 Amendment No.156 A.$ IdSed /AY y Io.t & O
I l t l l l Specification 3.6. I INSERT la A.s SR 3.6.1.1 -------------------NOTE------------------- The space between each dual ply bellows assembly on penetrations between the containment butEding and annulus shall be vented to the annulus during Type A tests. In accordance Perform required visual examinations and with the Type A leakage rate testing in accordance Containment with the Containment Leakage Rate Testing Leakage Rate Program. Testing Program SR 3.6.1.2 -------------------NOTE--------------------
- 1. Foilowing each Type A test, the space between each dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig to verify no O detectable leakage, or the assembly O shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa.
- 2. Type C tests on penetrations M372 and M373 may be performed without draining - - - - - NO TE- - - - - -
the glycol-water mixture from the seats SR 3.0.2 is not of their diaphragm valves if meeting a applicable zero indicated leakage rate (not ~~~~~~~~~~-~~-- including instrument error). In accordance Perform required Type B and C leakage rate with 10 CFR 50, testing, except for containment air lock Appendix J, testing and valves with resilient seals, in Option A, as accordance with 10 CFR 50, Appendix J, modified by Optton A, as modified by approved approved exemptions. exemptions l McGuire 2 Page A of (, t
QC'/r/ 2. / 7/7 8.0*/ . (CONTAffolEN'i SYSTEMS CONTAffolENT LEam_E
- LIMITfges enamfTI0h FOR OPERATION t
4.6.1.2 Containment leak == rates shall be limited to.]. [An ownrall integrated leakage rate of less than or equal t Soo MY OfIT5S,519 0.305 by weight of the containment air per 24 hours at P,. I4.8 psig, i A combined leakage rate of less than 0.60 L. for all penetrations I (Sft $. . l. \gand valves subject to Type B and C tests,~ wiien erssurized to p seg 4. J( ( A combined bypass leakage rate et less Wn 0.07 L, for all penetra i o f / 7 5 3. /,. tions identified pressurized to p as
. secondary containment bypass leakage paths when f
.I APPLICABIL YTY: MODES 1, 2, 3, and 4 t ACTIQN: gliHu cmStamentor.cyneNbb,ttslote l w M*~kf
/ Cr.2 cMstinnuf to DATABrf saltfes ik / dew
< *j g.n< hl': P[,p ' [aith (a) the measured overallsweac integrated 7d c
, d'"'"''+*'"''''"a'An'I lves aubtect ta T y e B and C bypass 'eaka t**+= **eaaM aa * ' " ' ' " ' ' ' ' ' '"' ""' '
ori(c) the combine ) 4:e.,, J :ge rate exceedino 0.07 L.,Jrestore sne ov M f ys p.4 3 .;reewgel'aws=',M.wan"2=*> ombined hvnans 1.=w==
, , , , wormes. rate- to less than 6 0 SURVEILLANCE REOUIRDIDITS m.-e q. ,5pfoVioMesiast#o , _, , .
s , _ O
~
4.6.1.2 10 CFR 50.54(o) and Appendix J of 10 CFR 50, option 8 exemptions Sec.Abfe/l{5p of fys ,5; $tember,,1995.and in accordance with the guidelines of Regulatory Guide 1.163 ( / *
*A one-time s granted to have the contai 't purge supply and/or exhaust isola valves for the upper and 1 j
3 and 4 fo compartment open in Mode ing the steam generator rep 1 A*) for hav days the valves open in Modes 3 t outase. The cumulativ time
.is limited to fourteen 1 other provisions of this fication apply with the ex(1 tion of se containment perse valves aled closed prior to initial in Modes 3 and 4. Each va e will be late Mode 2. j
/
McGUIRE - UNIT 2 3/4 6-2 Amendment No.156 I i p9e 3 of & O ,
\
. Sjetik bbt p.t 60NTAINME SYSTEMS
\SURVE CE RE00TR TS (Con nued). '
A,) l
- a. Delete
- b. Deleged l
' l E'
(SR3 4.51 e$ witf NrN 3N d Type 8 and C tests shall be conducted, in accordance with 10 CFR 50.54(o) and 10 CFR 50 Appendix J, Option A, with gas at P ,
/,
p olving:14.8 psig, at intervals no greater than 24 months except f Afr M M et ? J ,' "
- P 2 il a M eh**J" j'Ef"*4Y"'"' A sp exhaustisfotfon valv/with res}ffe3 ,
[ enT8 4 N30' Type C raining t ts performed without the gly on ontainment 1-water sixturepenetrati f s M372, M373 their imphrage valves F-228A, NF-2338, a the seats of e meet d leakage rata NF-234A),if t et r)g a zero indica w
- dina === valve < IThese(na+ arludine instra t
. I' sts may be us n
~
61 -Q.C.2(a) of 1p 50, Appendix J t4ubyof Section tests whis;l(are othe use air or mit n as 1 O [ , I l l l McGUIRE - UNIT 2 3/4 6-3 Amendment No.155 JNtf8 $8 h O
Sck'$tCallo'n j
- 5. 6./
fCONTAlmudr SYST . LLANCE*jIR , Conti _ $ rv te th *
' e N l f. / (e. 'pu se s xhaust is ation valves th rest 11 materi sted and strated by
. a Speciff , on 4.6.1.g or 4.6.1.9 . as applicable; re ts
_ qui ' II See N#rd, \ . The combined bypass leakage rate shall be determined to be less than d /73 E 'g except,for penetrations which are,not individually no dettetable leakage when tested with soap bubbles (tainment is pressartzed to P.,14.8 psig during each Type A test [ h . 1 The s e between each sal-ply bellows ssembly on cont inment
" 34I'IID ( h.
SM woe tions between containment 1dingandthean[nulusshall f ( ,w ted to the during Type i 1,tarf) of darM Ty w A ses tne space netwe tests. rFoll completton ~ a embly ssail be objected to a 1 pressure each dual-ply lows rtfy no detec le leakage or test 3-5 psig to subjected to leak test with dual-ply bell assembly shall ; e pressure on side of the d -ply bellows as ly at P containment I Q g,t leakage to be thin the Ifmit of Specific,14. psig to ati 4.6.1.2f. : verify the l
- d. ae rates shall N All test converted a * *Esolute calculated 1* value a n observed data a Erm r anal skallbeperformed lanced Integrat Leakage Meas t System; and j.
S!! N.ftgg,s c The provisions of 5;sification 4.0.2 are not applicabg i
/T5 f,S'8( ,
N6Ter W SJt h .\.'l w ; McGUIRE - IlllIT 2 3/4 6-4 Amendment No.155 o ,, aa
Discussian of Chtnges Sscticn 3.6 - Cantainment Systems ADMINISTRATIVE CHANGES 1 A.1 All reformatting and renumbering are in accordance with NUREG-1431. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant , operators as well as other users. The reformatting, renumbering, i l and rewording' process involves no technical changes to existing ] TS. Editorial rewording (either adding or deleting ) is made l consistent with NUREG-1431. During the Improved Technical Specifications (ITS) development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) to the TS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1431. Since the design is already approved by the NRC, adding more detail does not result in a technical change. A.2 CTS Surveillance Requirement 4.6.1.1.b requires each containment air lock to be in compliance with Specification 3.6.1.3 and l lP requires the containment air lock to be OPERABLE. Surveillance 4.6.1.1.b is redundant to CTS 4.6.1.3 and is eliminated. The ! containment air lock is addressed by CTS 3.6.1.3 and retained as ITS LC0 3.6.2. No technical requirements are modified by this , change and it is considered administrative. This change is I consistent with NUREG-1431. l l A.3 CTS 3.6.1.1, " Containment Integrity", CTS 3.6.1.2, " Containment Leakage", and CTS 3.6.1.6, " Containment Vessel Structural Integrity" are being combined into one Technical Specification and retained as ITS 3.6.1, " Containment." As a result, twoa ;ingl-e surveillance requirements arch created from the combination of the current requirements. ITS SR 3.6.1.1 and SR 3.6.1.2 maintains the overall technical requirement to perform leak testing and to verify structural integrity. The details of some of these requirements are located to the Containment Leakage Rate Testing Program. The reference to 24 months in CTS 4.6.1.2.d is not necessary since Types B and C testing are required at 24 months in accordance with 10 CFR 50 Appendix J, Option A. Technical changes to these CTS sections are discussed in other discussion of changes for this section. The change is administrative and is consistent with NUREG-1431. O McGuire Units 1 and 2 Page A - 17 Supplement 25/20/97l
Discussicn of Ching::s Section 3.6 - C:ntainment Systems
]
l TECHNICAL CHANGES - LESS RESTRICTIVE volve under administrative controls when it is required to be closed or declared inoperable to comply with ACTIONS. This exception is necessary to establish a concept that although utilized, is not formally recognized in the present Technical Specifications. Without the allowance, necessary repairs and testing could not be performed and the equipment would not be able to be restored to OPERABLE status. This change is consistent with NUREG-1431. L.31 CS 4.6.1.1.a and on associated footnote allaws certain
.:ntainment isolation valves to be opened under administrative control. ITS 3.6.3 includes a note to the ACTIONS which provides an allowance to open any containment isolation valve required to be closed (except for the large containment purge / exhaust valves) under administrative controls. This is acceptable based on the administrative controls consisting of a dedicated operator at the valve in continuous communication with the control room, or for volves with controls in the control room, a monitoring of containment isolation signal status. These controls provide protectton equivalent to the automatic isolation system. The large purge / exhaust valves are addressed by DOC L.30.
L.32 CTS 3.6.1.9 ACTION c requires restoring the inoperable valves to OPERABLE status. ITS 3.6.2 Required Action E.1 specifies isolating the affected penetration flow path by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange. The proposed change is a Less Restrictive change in that the CTS only allowed valve restoration to OPERABLE status, not penetration isolation. Isolating the offected penetration ensures the penetration flow path is performing its safety function and is on appropriate compensatory action. This change is consistent with NUREG-1431. L.33 CTS Surveiilance Requirement 4.6.1.1.c contains detalIs and requirements for Type B leak rate testing for penetrations which have been opened after testing. ITS SR 3.6.1.2 contains the broader requirement that all applicable Type B testing specified by 10 CFR 50, Appendix J, Option A must be met. The CTS requirement duplicates the requirements of 10 CFR 50, Appendix J, Option A section III.D.2 which requires that Type B penetrations be retested following opening. This change is acceptable since it O McGuire Units 1 and 2 Page L - 115 Supplement 25/2G/97l
f I Discussicn cf Chang:;s S::cticn 3.6 - C:ntainment Systems l' TECHNICAL CHANGES - LESS RESTRICTIVE V) l only eliminates a duplication of requirements and the CFR provides sufficient regulatory control over this activity. This change is consistent with NUREG-1431. l l l l l l l A L l l l McGuire Units 1 and 2 Page L - 125 Supplement 25/20/97l
Discussicn of Ch:ngis S;cticn 3.6 - C:ntainment Systems TECHNICAL CHANGES - REMOVAL OF DETAIM LA.1 CTS Surveillance Requirements 4.5.1.1.c, 4.6.1.2.c, 4.S.I.2.d.2, 4.6.1.2.d.4, 4.5.1.2.h, 4.6.1.2.1, and 4.6.1.6 contain details and exemptions for meeting the leak rate testing requirements stated in 10 CFR 50, Appendix J, Option B for Type A testing. ITS SR 3.6.1.1 contains the broader requirement that all applicable Type A testing and inspection specified by 10 CFR 50, Appendix J, Option B must be met, except for the ccatainment air locks. ITS 3.6.2 includes the requirements for the containment air locks. The specific acceptance criteria for Type A leakage rate testing l are retained in ITS 5.5.2. The details of how the requirements of 10 CFR 50 Appendix J, Option B are met are relocated to the l Containment Leakage Rate Testing Program. Approved exemptions are not necessary for inclusion within the TS. Changes to this program will be evaluated under the site procedure control program to ensure compliance with the CFR and approved exemptions. This change is consistent with the NUREG-1431 philosophy of relocating certain details outside of the TS. LA.2 The descriptive information in the CTS LC0 3.6.1.3.a. regarding OPERABILITY of the air locks, is being moved to the Bases for ITS O 2.6.2. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate for the Bases. The Bases are subject to the controls described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change in ITS 3.6.2 is consistent with NUREG-1431. LA.3 CTS Surveillances 4.6.1.3.a and b contain detailed information describing the airlock testing required by 10 CFR 50, Appendix J. This descriptive information is moved to the Bases and replaced with the ITS SR 3.6.2.1 which references 10 CFR 50, Appendix J, Option Athe Centainment Leakage Rate Testing Program. The frequency of testing is required by 10 CFR 50, Appendix J, Option A and the acceptance criteria are retained in ITS SR 3.6.2.&54. Other detail information contained in the CTS Surveillance, including any exemptions to 10 CFR 50, Appendix J, is relocated to the Basesplant precedures implementing the requirements. The l movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate for the Basesplant precedures. Any changes to these Basesdccument+ are controlled by the Basesprocedure control McGuire Units 1 and 2 Page LA - 1 Supplement 25/20/97l l 1
Na Significant H zards Ccnsid2ratien 5:cticn 3.6 - Ccntainment Systems LESS RESTRICTIVE CHANGE L.33 l The McGuire Nuclear Station is converting to the Improved Technical Specificottons (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change innives making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS Surveillance Requirement 4.6.1.1.c contains details and requirements for Type B leak rate testing for penetrations which have been opened after testing. ITS SR 3.6.1.2 contains the broader requirement that all applicable Type B testing specified by 10 CFR 50, Appendix J, Option A must be met. The CTS requirement duplicates the requirements of 10 CFR 50, Appendix J, Option A section 111.0.2 which requires that Type B penetrations be retested following opening. This change is acceptable since it only eliminates a duplication of requirements and the CFR provides sufficient regulatory control over this activity. This change is consistent with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposed change deletes material from the TS which is already contained in the CFR. Containment leukage is not assumed to be an initiator of any analyzed event. The containment leakage limitottons serve to 1imit the consequences of accidents. The proposed change does not reduce the containment leakage limits or requirements for testing and the consequences of design basis events as described in the UFSAR are not offected. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated. I O 1 McGuire Units 1 and 2 Page 6670 of 7170 Supplement 25/20/97l '
)
N3 Significant H:zards C:nsid:rsticn 5:cticn 3.6 - Centainment Systems i ( 2. Does the change create the possibility of a new or different kind l of accident from any accident previously evaluated? l The possibility of a new or different kind of accident from any l 7 accident previously evaluated is not created because the proposed i change does not introduce a new mode of plant operation and does not involve physical modification to the plant.
- 3. Does this change involve a significant reduction in the margin of safety?
The proposed change deletes material from the TS which is already contained in the CFR. The CFR provides sufficient regulatory controls to ensure that the requirements for testing Type B penetrations ofter opening is performed. Elimination of duplicated requirements does not offect any margin of safety. l O l l l l l l 1 McGuire Units 1 and 2 Page 67M of 71M Supplement 25/20/97l
i
'd Containment uitmson-;o. LLa- ~. - ic. Ice Usnoenser. nXcsnuan
- - - - . - - . - g __ . .&_
'At. s .re. f dwu.a wA ea F*~ h% Le% he t % ply fse b ; ea s nu la SURVEILLANCE REQUIREMENTL4 sj.u fe.,9 ,A 4.ptu. wp hytk..g_ , j9h n - ,
~
f SURVt1LLMLL ~ FREQUENCY SR 3.6.1.1 Perform required visual examinations and (---- TE- D " "" g 7
- A J 1eaka rate testing except for containment SR .0.2 is at O air 1 k testing, in accordance with
[0CtRou appenuix J. as moc 1eo licable ONC
#4/e approve exemptions. g/,
The eakage rate accepta e criterion is In accordance "J - s . 0 L, . However, dur' g the first uni with U Crx artup following tes ng performed in ix J a accordance with 10 50. Appendix J as ified Imodified by approv exemptions, the pprove leakage rate acc tance criteria ar < 0. xamnt' n
, for the Type and Type C tests and 0.75 L. for e Type A test.
MacA% SR 3.6.1 Verify containment tructural integrity In ecordance m\
<- in accordance wit the Containment Tendon w' h the 1
( Surveillance Pr am. ontainment ! endon i Surveillance Program WOG STS 3.6-2 Rev 1, 04/07/95 C Okurb )
l INSERT l l l SR 3.6.1.2 -----------------NOTE---------------_-- l l Following each Type A test, the space l l between each dual-ply bellows assembly I l shall be subjected to a low pressure l l test at 3 to 5 psig to verify no I detectable leakage, or the assembly I shall be subjected to a leak test with -----NOTE------ 1 I the pre m 'e on the containment side of SR 3.0.2 is not I the assembly at P,. applicable l l l Perform required Type B and C leakage In accordance with I l rate testing, except for containment 10 CFR 50, I L air lock testing and valves with Appendix J Option i l resilient seals, in accordance with A, as modified by I ! l 10 CFR 50, Appendix J, Option A, as approved I j l modified by approved exemptions. exemptions l l l ; l The leakage rate acceptance criterion l l l 1s s 1.0 L,. However, during the first l l unit startup following testing l l performed in accordance with 10 CFR 50, i l Appendix J, Option A, as modified by i ! approved exemptions, the leakage rate i I l acceptance criteria are < 0.6 L, for the l l l Type B and Type C tests. I
- l
? . l l l l i INSFRT Page 3.6-2 I McGuire
r l l l . , /) 0< Containment (IcaAnndawserJ B 3.6.1 BASES E APPLICABLE SAFETY ANALYSES (continued) 3$er day *in the safety analysis at P, = 114 psig h Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY. The containment .sa'tisfies Criterion 3reen -J enkca 1 Statement. . [ a un eso, yz, cae/ Q LCO Containment OPERABILITY is maintained by limiting leakage to s , , s 1.0 L., except prior to the first stutup after performing g a requiregm trw m. whanh o leakage test. At this-1 le yYAY (1 e $<Y W1 ) (, - Compliance with this LCO will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those
/ /' /,c leakage rates assumed in the safety analysis.
O *' b -- Individual leaka$, rates lock (LCO 3.6.2) purgespecified for resilient valves with the containment seals, andair secondary bypass leakage (LCO 3.6.3)I are not specificall @ part of the acceptance criteria of 10 CFR 50, Appendix J.y Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the acceptance criteria of i APPLICABILITY In MODES 1, 2. "3, and 4, a DBA could cause a release of l radioactive material into containment. In MODES 5 and 6, { the probability and consequences of these events are reduced due.to the pressure and tenperature liantations of these MODES. Therefore, containment is not required to be OPERAB8.E in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LC0 3.9.4, " Containment Penetrations." l (continued) WOG STS B 3.6-3 dev 1, 04/07/95 (Mc4 urc,) l
l I l i
& Contairnent (fce75ndemen 1
B 3.6.1 BASES (continued) I ACTIONS L1 l In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a period of time to correct the problem commensurate with the inportance of maintaining containment OPERABLE during MODES 1, 2. 3, and 4. This time p(eriod requiringalso ensuresODERABILITY) contairment that the probability of an occurring accident during periods when containment is inoperable is minimal. B.1 and B.2 j 1 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full
- p p wer conditions in an orderly manner and without allenging plant systems.
=
SURVEILLANCE SR 3.6.1.1 REQUIPIMENTS T9'A Maintaining the containment OPERAB requires compliance with the visual examinations and eakage rate test g, . requirements ofAJO LpH bit Annanm x e i n u U . a s mom hacii r . ov annrnv.o n.,* ions J Failure to meetyair lock 1, e ' Puk O kt c OM/m'McM s'e con'd ary containment bypass leakage path. and ource valve di'^ 4 W. l [ug Sile, / with resilient sealfiFaaka # N M E specified in LCO 3.6.2 ] s G g[ landLCO3.6.3Mdoesnotinvalidatetheacceptabilityof b'M b 1**"d l thd5h overallfleakage determinations unless thedb - - @a****3 contribution to evEi2T) Type A. B, ant C leakaoe causes f"4pi l 4 uo exc-VHmith. As left leakage prior to the firs (e -l (C,,,h w dh startuo after performing a requirad n mk w Aooendn I .
~ M u***H T my RJ< l leakage test is ired to beldA XrwthedAyM jN'" **%
y,"4 pg t v ar= g 0.75 L, for overarl Type A leaka - 4 all 'other time etween required leakage rate tests, t acceptance criteria is based on an overall Type A leakage Emv) an l
}/,u_,, 4 limit of s 1.0 L,. At s 1.0 L the offsite dose '
.,./ g se g a (At consequences are bounded by th,e assunptions of the safety h.Jdo m analysis. SR Frequencies are as required bypoenx a/ai SJ <ad=4<d mc <d ,,
((fs/ - 6,e Go,konmd teakaj W A-(, &/c 2h+4r &v continued) Wf WOG STS B 3.6-4 Rev 1, 04/07/95 O V (schw_,)
f3 Containment O~ c"trrih e! B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 (continued) l REQUIREMENTS *b ditipe Dy approveo e tions. Thus/SR 3 11nd Fra<uww v art < ions) rinac nnt/annivf.n 7 psen i l These periodic l testing requirements verify that the con'tainment leakage ! 4 - rate does not exceed the leakage rate assumed in the safety 1 analysis. QeJ5t"1t %._ _ l SR 3.6.1/[ For routed, post tensione tendons, this SR ensur s that the tructural integrity o the containment will . ma' tained in accordance ith the provisions of t e tainment Tendon Surv 11ance Program. Testi and h requency are consist t with the recomendati s of l Regulatory Guide 1. (Ref. 4). _ 1 REFERENCES 1. 10 CFR 50, Appendix J. 'O 2.@FSAR, Chapter $15h
- 3. @SAR, Section 46.2A (4. JWIgulatory Mde 1.35,JHivisiongg l
4A 10 UA 60.]G, hhnred Qcr de (c) C2)[ic )[ WOG STS B 3.6-5 Rev 1, 04/07/95 04dsEvG
I O: INSERT @ l The Surveillance it modified by a Note which requires that the space between i each dual-ply bellows assembly on containment penetrations between the I containment building and the annulus be vented to the annulus during each Type i A test. I l l l SR 3.6.1.2 I I Maintaining the Containment OPERABLE requires compliance with the Type B and C l leakage rate test requirements of 10 CFR 50, Appendix J Option A (Ref. 1), as I modified by approved exemptions. Failure to meet specific leakage limits for i the air lock, secondary containment bypass leakage path, and purge valve with I resilient seals as specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate I the acceptability of the overa'il containment leakage determinations unless the l i specific leakage contribution to Type A, B and/or C leakage causes one of I these overall leakage limits to be exceeded. As left leakage prior to the i first startup after performing a required 10 CFR 50, Appendix J, Option A, ! I leakage test is required to be < 0.6 L for combined Type B and C 1eakage. At I all other times between required leaka,eg rate tests, the acceptance criteria I is based on an overall Type A leakage limit of s 1.0 L . At s 1.0 L the I offsite dose consequences are bounded by the assumptio,ns of the safe,ty ; I analysis. SR Frequencies are as required by Appendix' J, Option A, as modified I by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) I does not apply. These periodic testing requirements verify that the OI containment leakage rate does not exceed the leakage rate assumed in the I safety analysis. i j i The Surveillance is modified by two Notes. Note 1 requires that following l i each Type A test, the space between each dual-ply bellows assembly be I subjected to a low pressure leak test with no detectable leakage. Otherwise, l I the assembly must be tested with the containment side of the bellows assembly l I pressurized to P and meet the requirements of SR 3.6.3.8 (bypass leakage l I rec,ui rements) . bote2allowspenetrationsM372andM373tobetestedwithout I draining the glycol-water mixture from the associated diaphragm valves (NF-l 228A, NF-233B, and NF-234A) as long as no leakage is indicated. This test may I be used in lieu of Section III.C.2(a) of 10 CFR 50, Appendix J, Option A which I requires air or nitrogen as the test medium. The required test pressure and I interval are not changed. I i All test leakage rates shall be calculated using observed data converted to I absolute values. Error analysis shall also be performed to select a balanced i integrated leakage measurement system. l INSERT Page B 3.6-5 (
Programs and Manuals 5.5 g 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained. 5.5.1 Offsite Dose Calculation Manual (ODCM1 The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program. Licensee initiated changes to the ODCM:
- a. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
- 1. sufficient information to support the change (s) together with the appropriate analyses or evaluations justifying the change (s), and
- 2. a determination that the change (s) do not adversely impact the accuracy or reliability of effluent, dose, or j setpoint calculations;
- b. Shall become effective after the approval of the Station I Manager; and
- c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made.
Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented. 5.5.2 Containment Leakaae Rate Testino 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, for Type A testing, as modified by l 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. (continued) V McGuire Unit 1 5.0-7 Supplement 2 l
! Programs and Manuals , 5.5 l 5.5 Programs and Manuals l
- (%
d 5.5.2 Containment Leakaae Rate Testina Proaram (continued) i The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 14.8 psig. The maximum allowable containment leakage rate, La, at Pa, shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 La.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance l criteria are < 0.75 La for Type A tests. The provisions of SR 3.0.2 do not apply to the test frequencies i specified in the Containment Leakage Rate Testing Program. 1 The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. ! i 5.5.3 Primary Coolant Sources Outside Containm^nt This program provides controls to minimize leakage from those l ih portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to J i l levels as low as practicable. The systems include Containment ! Spray, Safety Injection, Chemical and Volume Control, Nuclear Sampling, RHR, Boron Recycle Refueling Water, Liquid Waste, and Waste Gas. The program shall include the following:
- a. Preventive maintenance and periodic visual inspection requirements; and
- b. Integrated leak test requirements for each system at refueling cycle intervals or less.
I (continued) l McGuire Unit 1 5.0-8 Supplement 2
Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS lg)
'v' 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.
5.5.1 Offsite Dose Calculation Manual (0DCM) The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program. Licensee initiated changes to the ODCM:
- a. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
- 1. sufficient information to support the change (s) together with the appropriate analyses or evaluations justifying the change (s), and
- 2. a determination that the change (s) do not adversely
() v
,_ impact the accuracy or reliability of effluent, dose, or setpoint calculations; Shall become effective after the approval of the Station b.
Manager; and
- c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCH as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made.
Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented. 5.5.2 Containment Leakaoe 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, for Type A testing, as modified by l approved exemptions. This program shall be in accordance with the . guidelines contained in Regulatory Guide 1.163, " Performance-Based l Containment Leak-Test Program," dated September 1995. (continued) (q ~ x.__ l McGuire Unit 2 5.0-7 Supplement 2 l
l Programs and Manuals I 5.5 j 5.5 Programs and Manuals (D 5.5.2 Containment Leakaae Rate Testino Proaram (continued) The peak calculated containment internal pressure for the design l basis loss of coolant accident, Pa, is 14.8 psig. The maximum allowable containment leakage rate, La, at Pa, shall be 0.3% of ! containment air weight per day. , l Leakage Rate acceptance criteria are: )
- a. Containment leakage rate acceptance criterion is s 1.0 La. l During the first plant startup following testing in i accordance with this program, the leakage rate acceptance l criteria are < 0.75 La for Type A tests.
The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. 5.5.3 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those iO V portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include Containment Spray, Safety Injection, Chemical and Volume Control, Nuclear Sampling, RHR, Boron Recycle, Refueling Water, Liquid Waste, and Waste Gas. The program shall include the following:
- a. Preventive maintenance and periodic visual inspection requirements; and
- b. Integrated leak test requirements for each system at refueling cycle intervals or less.
I e (continued) b l McGuire Unit 2 5.0-8 Supplement 2 1
Specification 5.5.2 INSERT 4 5.5.2 Containment Leakage Rate Testing Program ! A program shall be established to implement the leakage rate testing of l the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, for Type A testing, as modified by approved l l exemptions. .This program shall be in accordance with the guidelines l contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995. l The peak calculated containment intemal pressure for the design basis loss of coolant accident, P., is 14.8 psig. The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 L..
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 L. l for Type A tests. l The provisions of SR 3.0.2 do not apply to the test frequencies specified l t in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage l Rate Testing Program. 1 l 1 i McGuire l Page ll of (,9
SW,ecuark I. f.'2. de a 4 e %t f.A J' a w Ka T *'- l*SN'] b d *"'- f. S' 2. ONTAllefENTSYSTEM5] . CONTAlletENT LFAKAdE O LIMITIIICCONDITIONFOROPERATM
~
(L6.1.2 ContainmentleakageratesshallbeIfmitedtod A' 8~c W =l' 2,.a p ~r"' @ An overall integrated leakage rate of'less than er equal to L.,
#d #4 O.30% by weight of the containment air per 24 hours at P*,
14.8 psig, i 3 4e n 2. l
@ fA combined leakage rate of less than 0.60 for all penetrations i
valves subject to Type B and C tests, en pressurized to P ,
- c. A combined bypass leakage rate of less than107 L for all penetra-
%),g tions identified as secondary containment bypass leakage paths when pressurized to P,. ~
g APPLfCARILfTY: MODES 1, 2, 3, and 4.* l ACTION:
,adel J .b ,
5.I. 2..A With (a) the measured overall integrat 1 [ containment leakaae rate exceeding 0.75 L or (IMthe measured combined leakage rate for all TeTranons ana - pvalvessubjecttoTypesBandCtestsexceedina0.60L., Qypass_ leakage rate exceco mg u.U/ ic) tne combined 3 e y- LRestore the overaT) integrateo leau (Sgg u, (rat,Oto less~ than 0.75 L. and the combinedJilkige rate iur aii penetratio g,t,,1 ** and valves subject to Type B and c- tests to less than 0.60 L.,j_ano Ine *N, combinea oppass leakage rate to less Lnan v.vi L Reactor Coolant System temperature above 200'F. ,fprior so increasing the O ggg, i SURVEILLANCE RE0UTREMENTS a gaA .1. to Type A containment leakage rates shall be demonstrated as required by ydp.,Ng
- r. .54 o) and Appendix J of 10 CFR 50, Option B, as modified by approved exemptions, a(nd in accordance with the guidelines of Regu September, 1995.
.one-time change is granted to have the containment purge supply and/or exhaust isolation valves for the upper and lower compartment open in Modes 5'* **'" f ' 3 and 4 following the steam generator replacement outage. The cumulative time 41T3 3.t. l for having days. the valves open in Modes 3 and 4 is liatted to fourteen (14)
A11 ether provisions of this specification apply with the exception of those containment purge valves open in Modes 3 and 4.
% sealed closed prior to initial entry into Mode 2. Each valve will be i 1
McGUIRE - UNIT 1 3/4 6-2
. Amendment No.174 1
944 Ac,+rsk
~
S .C .'2 l . l INNENT SYST SURVEILLANCE REOUIREMENTS (Continued) b# a. Deleted forIT53.6.l/ - ! b. Deleted (. l l c.
, The accuracy of each Type A test shall be verified by a supplemental test in accor11ance with Regulatory Guide 1.163, September, 1995, I
a y l
@ [50.54(o) and 10 CFR 50 Appendix J, Type 8 and C tes tion A, with gas at p 1
$ '* ' # 14.8 avolphg: ig, at intervals no greater t an 24 months except fo.,r tests
[ 1) Air locks,
- 2) Dual-ply bellows assembifes on containment penetrations between the containment building and the annulus, and
- 3) purge supply and exhaust isolation valves with resilient material seals.
.5s*ww l 1
fe .7T5 3.f..I 4) Type C tests performed on containment penetrations M372, H373 without draining the 31 col-water mixture from the seats of their diaphragm valves NF-228A, NF-233B, and NF-234A), if ) meeting a zero indicated leakage rate (not including instrument error) for the di hrage valves. These tests may be used in lieu of tests whi are otherwise required by Section Ilf.C.2(a) of 10 CFR 50, Appendix J to use air or nittsgen as 4 3 0 . l l McGUIRE - UNIT 1 3/4 6-3 Amendment No.173 1 l'] b o 1 l
i h e c<wA~ ONTAINMENT SYSTEMS i I CONTAINMENT AIR LOCKS LIMITING CON 0! TION FOR OPERATION 6e.e. & g 7 s n y,( 3.6.1.3 Each containment air lock shall be OPERABLE with: ')
- a. Both doors closed except when the air lock is being used for normal transitentryandexitsthroughthecontainment,thenatleastong air inek dnne chall he closed and _ -
l f e * % An overall air lock leakage rate of less than 0.05 L, at P ,14.8
, 2. , tpsig. !
I PPLICABILITY: MODES 1,2,3,an] A ACTION:
- a. With one containment air lock door inoperable:
- 1. Maintain at least the OPERABLE. air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours or lock the OPERABLE air lock door closed.
- 2. Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days,
& Ji3 7.4. 3. Otherwise, be~in at least HOT STANOBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours, and
- 4. The provisions of Specification 3.0.4 are not applicable. ,
. With the containment air loc'. inoperable, except as the result of an inoperable tir lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
i
. McGUIRE - UNIT 1 3/4 6-5 Amendment No. 166 i I
O wu n l 1
[f un co CMo ONTAINMENT SYSTE D I' I* A SURVEILLANCE REOUIRENENTS a
.15 . 1 . 3 Each containment air lock shall be demonstrated OPERABLE:
i a. Within 72 hours following each closing, except when the air lock is T l A .
- being used for multiple entries, then at least once per 72 hours, by 1 verifying that sne3eal leakaae is less than 0.01 L3as determined l
l k- by precision flow measurements when measured for at least 30 seconds with the volume between the seals at a constant pressure of 14.8 ! Psig,
- b. By conducting overall air lock leakage tests at not less than P,,
14.8 psig, and verifying the overall air lock leakage rate is within its limit:
- 1) At least once per 6 months, i and )
i
- 2) Prior to establishing CONTAINMENT INTEGRITY when maintenance l has been performed on the air lock that could affect the air lock sealing capability.*
- c. At least once per 6 months by verifying that only one door in each j air lock can be opened at a time, and j
- d. At least once per 6 months by conducting a pressure test to verify l ggg door seal integrity, with a measured leak rate of less than I p g g,4; 15 standard cubic centimeters per minute. j O. i l
l
/
iThe provisions of Specification 4.0.2 are not applicable.
*This constitutes an exemption to Appendix J of 10 CFR 50. ,
. McGUIRE - UNIT 1 M Amendment No. 166 i
l I 7c. I
Specification 5.5.2 INSERT 4 f-
/\
G1 5.5.2 Containment Leakage Rate Testing Program 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, for Type A testing, as modified by approved l 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. The peak calculated containment intemal pressure for the design basis loss of coolant accident, P.,is 14.8 psig. The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 L.,
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 L. l for Type A tests I The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. O McGuire 2- Page Ilof loS L
QS,'t. Gentekn t In rue, Me resrAs PwQ _. Spos.c e.ns% 5 C2 CONTAffetDff SYSTEMS p CONTAffffENT LFMAcE O & In,14.1 LIMITIIIG rmafT10h FOR OPERATION \ w {.6.1.1 Containment leakage rates shall be limited to:l h ja 4 -@ 2/An overall integrated leakage rate of less than or equal to gg[ of 5.f. 2. 0.305 by weight of the containment air per 24 hours at P., 4.8 psig, g '^ @ A combined leakage rate of less than 0.60 valves subject to Type 8 and C test or all penetrations pressurized to p., (U.h [ r.c A combined bypass leakage rate of less than 0.07 L g tions identified press,urized to P . as secondary containment bypass leakage paths w 4,T b M.] , APPLICABILffY: MODES 1, 2, 3. and d * (ACTION: j l
,31 T g '^ nlith (a .
vsL2^ nME~subt )orAb) Ene ==%.c combined leakage rate valves \ for ai1 \ M Uypass Tu ject to Types 8 and C tests erraadino o_sa L- aryc
. the e* ned )Trnu.3/
AI 'l 'l Catetto _ -- rese -- =ang u.vi tJann une _..i.;; .
- aeo m e, xao =m
- ess snan 0.75 L ano the combinedHeat rate for a' penetrat'ons
_ and valves E-anen -r 55subject
<----;:to,.6.
Type B ana_C tasts to less than 0.60 kJana m M .,1 6e esa saan v.97 (Reactor Coolant system +---arature above 200*F.y prior to increasing the SURVEILtANCE RE00fREMENTS
-r see-a-r \
' ezrs t.s. ll
.b,3f
- g '^
~
tar W et 3.5.1 50.54(o) and Appendix J of 10 CFR 50, Option 8 exemptions and September,,1995. in accordance with the guidelines of Regulatory Guide 1.163, ( ~ -
*A one-time change is granted to have the containmen't purge supply and/or exhaust isolation valves for the uppe I -
3 and 4 following the steam generator.r and lower compartment open in Modes 5=* ***f replacement outage. 4.<3T53.L.) for having the valves open in Modes 3 and 4.is limited to fourteenThe cumulative tim days. All other provisions of this specification apply with the14)exc(eption of those containment purge valves open in Modes 3 and 4. sealed closed prior to initial entry into Mode 2. Each valve will be McGUIRE - UNIT 2 3/4 6-2 Amendment No.156
& GA EY ;
. $ae4pewr'b
- 5. f.1 CONTAINMENT SYSTEM O. ( SURVEILLANCE REOUIRENENTS (Continuedb I
~
- a. Deleted 9* "W b. Deleted g w ss.t.1 c.
The accuracy of each Type A test shall be verified by a su ml C test in accordance with Regulatory Guide 1.163. September,pplementall Ag 1995. J 85 *
@("Yype B and C tests shall be conducted, in accordance with 10 CFR i 50.54(o) and 10 CFR 50 Appendix J. Option,&. with gas at P .
F . involving:14.8 psig, at intervals no greater than 24 months except for te T Air locks,' ' 2) Dual-plybellowsassedliesoncontainmentpenetrationsbetween) the containment building and the annulus, and 3) Purge supply material seals.and exhaust isolation valve's with resilient
#"M 4) 4 r53J.I without draining the giType C tests performed on containmen their diaphragm valves ol-water mixture from the seats of meeting a zero~indicat' F-228A, NF-2338, leakage rate and NF-234A error) for the diaphragm valves. .These(not including i strument )
lieu of tests which att otherwise required by sectiontests may be used in O 'III.C.2(a) of 10 CFR 50, Appendix J to use air or nitrogen as J i I I a I l l 1 1 McGUIRE - UNIT 2 3/4 6-3 Amendment No.155 O n os s a
(CONTAINNpfT $YSTEMS &mr*5p,g,L. CONTAlletENT AIR LOCKS . O See waaf
& ITS.%
LIMITING CONDITION FOR OPERATION L 3.6.1.3 Each containment air lock shall be OPERA 8LE with:
- a. Both doors closed except when the air lock is being used for normal transit entry and exits through the containment, then at least one air lock door th=11 he closed. and -
I .
@[An overall air lock leakage rate of less than 0.05 L, at P,,14.8 (psig. '
- [ APPLICABILITY
- MODES 1, z, 3, arm .3
\
\ l AC110E: I
- a. With one containment air , lock door inoperable:
- 1. Maintain at least the OPERA 8LE air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours or lock the GPERABLE air lock door closed, .
- 2. Operation may then continue until performance of the next !
required overall air lock leakage test provided that the OPERA 8LE air lock door is verified to be locked closed at least 3g once per 31 days, ,
- 4. Trs 7.C.Z 3. Otherwise, be in at least HOT STAND 8Y within the next 6 hours and in COLD SHUTDOWN within the following 30 hours, and
- 4. The provisions of Specification 3.0.4 are not applicable.
- b. With the containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable ' air lock to OPERABLE status within 24 hours or be in at least HOT STAND 8Y within the next 6 hours and'in COLD SHUTDOWN within the following 30 hours.
A 1 l l l McGUIRE - UNIT 2 3/4 6-5 Amendment No. 148 fT
NMENT SYSTEMS f& w b5, f, L i SURVEILLANCE REOUIREMENTS O 4.4.1.3 Each containment air lock shall be demonstrated OPERABLE:
- a. Within 72 hours following each closing, except when the air lock is
' being used for multiole entries, then at least once per 72 hours, by verarying tnat tnedeal leakage is less than 0.01 L7s determined I by precision flow measurements when measured for at'least 30 seconds with the volume between the seals at a constant pressure of 14.8 Psig,
- b. By conducting overall air lock leakage tests at not less than P ,
14.8 psig, and verifying the overall air lock leakage rate is w$ thin its limit:
- 1) At least once per 6 months, # and
- 2) Prior to establishing CONTAlle4ENT INTEGRITY when maintenance has been performed on the air lock that could affect the air lock sealing capability.*
l
- c. At least once per 6 months by verifying that only one door in each/
air lock can be opened at a time, and
.See mf 4 m 4.4.2. d. At least once per 5 months by conducting a pressure test to verify door seal integ ity, with a measured leak rate of less than 15 standard cub c centimeters per minute.
I l
#The provisions of Specification 4.0.2 are not applicable.
*This constitutes an exemption to Appendix J of 10 CFR 50.
McGUIRE - UllIT 2 3/4 6-6 Amendment No. 148 m 17c of 41
Discussien of Chingts Chipter 5.0 - Administrative Centrols ADMINISTRATIVE CHANGES A.28 CTS 4.4.5.4.a.8 definition of tube inspection has been revised to clarify that the inspection encompasses the entire tube from entry to exit and is not dependent on where the inspection starts, i.e. it may start on either the hot or cold leg side. This has always been interpreted to allow inspection from either side, however, a literal reading of the CTS could be misinterpreted. This change is incorporated into ITS 5.5.9.4.a.8. A.29 CTS 6.12.1 and 6.12.2 have been revised to change the point of measurement for the radiation field from 45 cm (18 in.) to 30 cm (12in.). This change is consistent with 10 CFR 20.1601 and is considered administrative. The measurement point only provides a consistent reference to baseline field strength and has no affect on how the plant is operated. 1 A.30 CTS 6.9.2 has been deleted. LC0 actions requiring special reports l to be generated have been specifically identified in the Administrative Controis, e.g. PAM report. This change is administrative and consistent with NUREG-1431. A.31 CTS 6.8 has been revised to include the Containment Leakage Rate Testing Program. The ITS 5.5.2 program maintains the acceptance criteria in CTS 3.6.1.2 =d 3.5.1.3. The addition of the program l is considered administrative in nature since it only moves acceptance criteria from one location to another within the TS. Any changes in technical detail will be discussed in the i Description of Changes for Section 3.6. This change is consistent ! with the program in the NRC model for implementation of option B to 10 CFR 50, Appendix J, enclosed in a letter from C.I. Grimes, NRC, to D.J. Modeen, NEI, dated November 2,1995 for Type A tests. l A.32 The responsibility for maintaining keys for high radiation areas in CTS 6.12.2 has been changed from radiation protection supervision to radiation protection personnel. The CTS could be incorrectly interpreted to imply that responsibility is assigned to a " Supervisor" or manager. Current plant practice does not maintain management personnel within radiation protection on back shifts, however, the keys are under the control of radiation protection personnel on duty. The ITS 5.7.2 provides a clarification only and is considered administrative in nature. McGuire Units 1 and 2 Page A - 78 Supplement 25/20/97l
INSERT 5 5.5.2 Containment Leakage Rate Testing Program , A program shall be established to implement the leakage rate l testing of the containment as required by 10 CFR 50.54(o) and 10 l CFR50,AppendixJ,OptionB,forTypeAtesting,asmodifiedbyl approved exemptions. This program shall be in accordance with . the guidelines contained in Regulatory Guide 1.163, I I
" Performance-Based Containment Leak-Test Program," dated >
l September 1995. The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 14.8 psig. l The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 L,.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 L, for Type A tests. b The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. 1 The provisions of SR 3.0.3 are applicable to the Containment l Leakage Rate Testing Program. l l INSERT Page 5.0-8 McGuire i E 2-
Justificatien fcr DIviaticns Ssction 5.0 - Administrativa Centrols O V TECHNICAL SPECIFICATIONS
- 10. Duke Power has elected not to submit a PTLR at this time. The current TS values and limits will remain in the proposed TS. All references to a PTLR have been deleted from the proposed TS.
- 11. This change reflects the NRC model for implementation of option B to 10 CFR 50, Appendix J, enclosed in a letter from C.I. Grimes, NRC, to D.J.
Modeen, NEI, dated November 2,1995 for Type A tests. l
- 12. The change from " greater than or equal to" to " greater than" is consistent with the referenced Branch Technical Position.
- 13. The current TS for ventilation systems permit continued operation with an inoperable heater provided a special report is provided to the NRC within 30 days. The proposed report is consistent with the current TS and is provided in a format consistent with similar reports in NUREG-1431.
- 14. The reference in Section 5.6.7 to specific conditions of LC0 3.3.3 is deleted. This format is not necessary to ensure the required report is generated. References to specific conditions within other specifications has the potential to cause unintentional cross-reference errors in future amendments.
- 15. The 5.5.11 requirements for ventilation filter testing in accordance l with Regulatory Guide 1.52 and ANSI N510 are revised. Exceptions to l these documents exist in the UFSAR as a part of the approved licensing basis. These exceptions are specifically identified in the UFSAR for each filter unit.
l 16. This change reflects a generic change to NUREG-1431 approved by the NRC as proposed in TSTF-119. l 17. This change reflects a generic change to NUREG-1431 approved by the NRC
- as proposed in TSTF-118.
l l 18. This change reflects a generic change to NUREG-1431 approved by the NRC l as proposed in TSTF-152. O V McGuire Units 1 and 2 2+ Supplement 26/20/W l j
McGuire & Catawba Improved TS Review Conenents ITS Section 3.6, Containment Systems 3.6.1 -3 DOC A.5 (ITS 1.0) DOC LA.1 JFD Bases.1 JFD Bases 2 (McGuire only) CTS 1.7 CTS 4.6.1.2.d.3) CTS 4.6.1.2.h STS B3.6.1 Bases BACKGROUND ITS B3.6.1 Bases BACKGROUND CTS 1.7 provides the definition for Cor,tainment integrity and is justified by DOC A.5 as deleted in the CTS Markup of ITS 1.0. This is incorrect. The definition is part of the technical specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.7 should be included in the CTS Markup of ITS 3.6.1, 3.6.2 and 3.6.3. In particular, all l of CTS 1.7 (a through e, except d, is relocated to ITS B3.6.1 Bases - BACKGROUND. This ' change would be considered as a Less Restrictive (LA) change. In addition, ITS B3.6.1 Bases BACKGROUND shows that STS B3.6.1 Bases - BACKGROUND item d has been deleted. Based on CTS 1.7.e,4.6.1.2.d.3), and 4.6.1.2.h, this item cannot be deleted. Furthermore, CTS 1.7a, c and e should also indicate that they are associated with other ITS 3.6.1,3.6.2, and 3.6.3 SRs which are Administrative changes. (See Comment Numbers , 3.6.21 and 3.6.3-1) Comment: Revise the CTS markup of ITS 3.6.1 to include a markup of l O CTS 1.7 and revise ITS B3.6.1 Bases BACKGROUND, accordingly. Provide additional discussion and justifications for the above Less Restrictive (LA) and Administrative changes. DEC Response: CTS 1.7 has been added to the CTS Markup for ITS Section 3.6. LA25 has been added to the Discussion of Changes for CTS 3.6 to justify the movement of this infonnation to the i Bases of ITS 3.6.1. CTS 1.7 item d is shown as being captured by the surveillance ! requirement for ITS 3.6.1. No specific administrative changes beyond the general formatting change (A.1) is necessary. It is not necessary to include this markup in any other 3.6 specification markup since all CTS 1.7 detail is associated with the Bases of ITS 3.6.1. mc3_cr_3.6 3.6-3 March 12, 1998
f Containment B 3.6.1 BASES l BACKGROUND The isolation devices for the penetrations in the (continued) containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:
- a. All penetrations required to be closed during accident conditions are either:
- 1. capable of being closed by an OPERABLE automatic containment isolation system, or i I
- 2. closed by manual valves, blind flanges, or de-activated automatic valves secured in their i
]* $ so.l
- 3 muh& . closed positions, except as provided in gy. LCO 3.6.3, " Containment Isolation Valves";
%b (M.) M 1,chus,,,o.esd
- b. Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks"; g
- c. All equipment hatches are close Q APPLICABLE The safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting Design Basis Accident (DBA) without exceeding the design leakage rates. I 1
The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures are a loss of coolant accident (LOCA) and a steam line break (Ref. 2). i In addition, release of significant fission product i radioactivity within containment can occur from a LOCA. In i the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.3% of containnent air weight per day (Ref. 3). This leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in 10 CFR 50, Appendix J (Ref.1), as L,: the maximum allowable containment leakage rate at the calculated peak containment internal pressure (P,) resulting from the limiting design basis LOCA. The allowable leakage rate represented by L, , forms the basis for the acceptance I (continued) McGuire Unit 1 B 3.6-2 h pfame,J 2- 5#0/97
Centainment B 3.6.1 BASES BACKGROUND The isolation devices for the penetrations in the (continued) containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:
- a. All penetrations required to be closed during accident conditions are either:
- 1. capable of being closed by an OPERABLE automatic containment isolation system, or
- 2. closed by manual valves, blind flanges, or r de-activated automatic valves secured in their d.'the.wbymed*,dm closed positions, except as provided in gg g, , A. LCO 3.6.3, " Containment Isolation Valves";
PMW U+M' b. Each air lock is OPERABLE, except as rovided in htH%.,0-rM LCO 3.6.2, " Containment Air Locks"; ns 09ESAM. A I
- c. All equipment hatches are close Q L
The safety design basis for the containment is that the O APPLICABLE SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting Design Basis Accident (DBA) without exceeding the design leakage rates. The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures are a loss of coolant accident (LOCA) and a steam line break (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a LOCA. In the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.3% of containment air weight per day (Ref. 3). This leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in 10 CFR 50, Appendix J (Ref.1), as L,: the maximum allowable containment leakage rate at the calculated peak containment internal pressure (P,) resulting from the limiting design basis LOCA. The allowable leakage rate represented by L, forms the basis for the acceptance (continued) McGuire Unit 2 8 3.6-2 Svpfl eech L -6#0/97-
pecMc., 3.(..I DEFINITIONS CONTAINMENT INTEGRITY O V d.7 CONTAINMENT INTEGRIIY sh 1 exist when:
- a. All penetrations required to be closed during accident to itions areT either:
- 1) Capabl of being closed by an OPERABLE containme automatic isola ion valve system, or operator action duri periods when con inment isolation valves may be opened und r administrative co rois pursuant to Specification 4.6.1.1.a; or
- 2) losed by manual valves, blind flanges, or eactivated automatic valves secured in their closed positions.
- b. 1 (quipment hatches are closed and sealed,
- c. Each air lock is in compliance with the re frements of Specification 3.6.1.3.
- d. The containment leakage rates are within the limits of Specification 3.6.1.2, and
- e. Theseal[ngmechanismassociatedwitheachpenetra1on(e.g.,
/ welds, /
bellows 4 or 0-rings) is OPERABLE. / j CONTROLLED LEAKAGE 1.8 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor coolant pump seals. CORE ALTERATION 1.9 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of See meQ movement of a component to a safe conservative position. , b IT51.0 j CORE OPERATING LIMITS REPORT 1.10 The CORE OPERATING LIMITS REPORT (COLR) is the unit-specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for eacn reload L cycle in accordance with Specification 6.9.1.9. Unit operation within these perating limits is addressed in individual specifications. McGUIRE - UNIT 1 1-2 Amendment No. 166 O y .o
SpecWA 3.L.) DEFINITIONS CONTAINMENT INTEGRITY p & ~ 1.7 CONTAINMENT INTEGRITY hall exist when:
- a. All penetratio required to be closed during accident nditions are either:
- 1) Capab of being closed by an OPERABLE contain it automatic isol tion valve system, or operator action dur ng periods when co aineerit isolation valves may be opened u er administrative ntrols pursuant to Specification 4.6.1.1. , or
- 2) Closed by manual valves, blind flanges, o deactivated automatic
, valves secured in their closed positions LA W i
- b. All equipment hatches are closed and seale
/
c Each air lock is in compliance with the quirements of Specification 3.6.1.3,
- d. The containment leakage rates are within the limits of Specific 3.6.1.2, and
- e. The sealing mec nism associated with each penetration (e g., welds, bellows, or 0 ings) is OPERABLE.
ROLLED LEAKAGE 1.8 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor coolant pump seals. CORE ALTERATION 1.9 CORE ALTERATION shall be tb movement or manipulation of any component fee. % M \ within the reactor pressure vessel with the vessel head removed and fuel in the C m'o vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position. CORE OPERATING LIMITS REPORT 1.10 The CORE OPERATING LIMITS REPORT (COLR) is the unit-specific document ; that provides core operating limits for the current operating reload cycle. I These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Specification 6.9.1.9. Unit operation within these operating limits is addressed in individual specifications. Y _-
)
McGUIRE - UNIT 2 1-2 Amendment No. 148 l 0 - wa,
Discussien of Changss S:ctien 3.6 - C:ntainment Systems TECHNICAL CHANGES - REMOVAL OF DETAILS LA.23 CTS 4.6.3.2 requires performance of containment isolation valve testing during cold shutdown or refueling. This detail is not required within the TS to demonstrate operability and is relocated to the BASES for ITS SR 3.6.3.76. The Bases are subject to the l controls described in Chapter 5 " Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.24 CTS 4.6.2.b requires the containment spray pump meet a specified value when tested pursuant to Specification 4.0.5. ITS SR 3.6.6.2 requires that the pumps develop the required head pressure required by the Inservice Testing Program. Relocation of the required pressure to the Inservice Testing Program is acceptable since this program must meet the requirements of 10 CFR 50.55a. Changes to the procedures which implement these requirements are controlled by the procedure change prograa. These controls ensure that changes are appropriately reviewed and conform to 10 CFR 50.55a requirements. These changes do not change any technical requirements or change the present way of performing these O surveillances and are therefore considered administrative. These changes are consistent with NUREG-1431. LA.25 CTS 1.7 items o, b, c, and e define the attributes of containment operability and integrity. These attributes have been relocated to the Bases for ITS 3.6.1. The descriptive attributes are more appropriate information for Bases and are not necessary to be included within the Technical Specification. The requirement to maintain on operable containment is retained in ITS 3.6.1. The Bases are subject to the controls described in Chapter 5
" Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with ,9UREG-1431.
LA.26 Descriptive informatton regarding the containment personnel access doors and hatches in CTS 3.6.5.5 and the divider barrier seal in CTS 3.6.5.9 is moved to the Bases for ITS 3.6.14. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate for the Bases. The Bases are subject to the controls l McGuire Units 1 and 2 Page LA - 7 Supplement 25$0/97t l
U Containment Geefonde@ g B 3.6.1 BASES BACKGROUND a. All penetrations required to be closed during accident (continued) conditions are ei,ther:
- 1. capable of being closed by an OPERABLE automatic containment isolation system, or
- 2. closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LC0 3.6.3. 'Contairinent Isolation Valves";
- b. Each a'- lock is OPERABLE. except as provided in LCO 3.6.2. ' Containment Air Locks"; Q l
- j. w /cLa.p
- c. All equipment hatches are closed; @ l / ,
i The6ressurbeds aling mechanism a[snciated with a penetration 1s erable CeKCelure>@rpfdarria 1
<Lco Q .6 O . F /
i _) vTe.9., wb Art.w , ., o- .bh
~
u l
/] APPLICABLE The safety design basis for the containment is that the Q MFETY ANALYSES containment must withstand the pressures and temperatures of the limiting y without exceeding the design leakage rates.
Desyn 84516 The DBAs that result in a challenge to containment Am/ cad (066 OPERABILITY from high press res and tenperatur are a is coo.am aceweent f1 a steam line brea C2 miwwon acament 14 TAT)( t. 7). In addition, re ease of significant fission product radioactivity within containmen ; can occur from a LOCA In the DBA analyses, it is assumed that the conta @inment is OPERABLE such that, for the, DBAs involving release of fission product radioactivity, a3 g release to the envirorsnent is controlled by the rate of containment leakage. The containment was designed with an 4 allowable leakage rate of M.i containment air weight per day.(Ref. 3). This leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in 10 CFR 50. Appendix J (Ret.1), as L,: the maxinun allowable containment leakage rate at the calculated peak containment internal pressure (P ) resulting from the limiting W D. The allowable leakage rate represented by L hrs be5 4AAj, forms tfi,e basis for the acceptance criteria imposed on all, containment leakage rate testing. L, is asstaned to be (continued) WOG STS B 3.6-2 Rev 1. 04/07/95 hc4mrO i l
l McGuire & Catawba Improved TS Review Comunents ITS Section 3.6, Containment Systems O 3.6.2 Containment Air Locks 3.6.2-1 DOC A.5 (ITS 1.0) CTS 1.7 l See Comment Number 3.6.1-3. Comment: Revise the CTS Markup of ITS 3.6.2 to include a l markup of CTS 1.7. Provide additional discussions and justifications for the Administrative I changes. ' DEC Response: See response to Comment 3.6.1-3. I O i l l mc3_cr_3.6 3.6-4 March 1., 1998
McGuire & Catawba Improved TS Review Coments ITS Section 3.6, Containment Systems 3.6.2-2 DOC A.9 DOC LA.3 DOC LA.4 I JFD 6 JFD Bases 6 CTS 3.6.1.3.b CTS 4.6.1.3a, b, and d. ITS SR 3.6.2.1 ITS B3.6.2 Bases See Comment Number 3.6.1-2. Comment See Comment Number 3.6.1-2. DEC Response-DOC LA.3 and LA.4 have been revised to indicate that the CTS 4.6.1.3.a. 4.6.1.3.b, and ) 4.6.1.3.d detail have been relocated to the Bases. The frequency of testing is already I established by 10 CFR 50, Appendix J, Option A and is not necessary to be repeated in the surveillance. The Bases provide an appropriate place to locate the details of the sealleak testing which are in addition to the requirements of the CFR. ITS SR 3.6.2.1 and associated Bases are revised to conform to the STS. DOC A.9 has been revised to delete references to the leak rate testing program and to Option B. ITS 5.5.2 and associated CTS markup have O been revised to delete the air lock acceptance criteria from the Containment Leakage Rate Testing Program. I j mc3_c r_3.6 3.6-5 March 12, 1998
Containment Air Locks 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 -------------------NOTES---- -------------- 1.- An inoperable air lock do does not invalidate the previous suc sful p *formance of the overall air ock lea a e test.
- 2. Results all be evaluated against acceptance riteria applicable to ldgT SR 3.6.1.1.
Perform required air lo(k leakage rate In a cordance testing in accordance wit the Containment with e LeakageRateTestingProg(ram. Contain nt Leakage (te TestingPryram a SR 3.6.2.2h Verify only one door in the air lock can be 18 months ] opened at a time. O McGuire Unit 1 3.6-7 Sst/b i h 5/20/07 -
INSERT O SURVEILLANCE FREQUENCY SR 3.6.2.1 -------------------NOTES-------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in accordance with 10 -----NOTE------
CFR 50, Appendix J, Option A, as modified by SR 3.0.2 is not approved exemptions. applicable Perform required air lock leakage rate testing in In accordance l accordance with 10 CFR 50, Appendix J Option A, as with 10 CFR 50, 1 modified by approved exemptions. Appendix J, Option A, as ! The acceptance criteria for air lock testing are: modified by approved
- a. Overall air lock leakage rate is s 0.05 L, exemptions f
when tested at a P,.
- b. For each door, leakage rate is < 0.01 L, when tested at 2 14.68 psig.
SR 3.6.2.2 Perform a pressure test on each inflatable air 6 months i lock door seal and verify door seal leakage is
< 15 sccm.
O
Containment Air Locks 3.6.2 O SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 ----
\ ------------NOTES----------- ------
- 1. A noperable air lock door does ot inv idate the previous successful perfo nce of the overall air lock leakage test.
- 2. Results sh 11 be evaluated against acceptance cTiteria applicable to SR 3.6.1.1.
y+ -------------------- ---------------------- Perfonn required air lo leakage rate In accor nce testing in accordance wit the Containment with the Leakage Rate Testing Progr . Containment Leakage Rate Testing Prog am , SR 3.6.2. Verify only one door in the air lock can be 18 months ! opened at a time. O r McGuire Unit 2 3.6-7 g/// M
INSERT O , SURVEILLANCE FREQUENCY SR 3.6.2.1 ------------------NOTES-------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in accordance with 10 -----NOTE------
CFR 50, Appendix J. Option A, as modified by SR 3.0.2 is not approved exemptions. applicable Perform required air lock leakage rate testing in In accordance accordance with 10 CFR 50, Appendix J Option A, as with 10 CFR 50, modified by approved exemptions. Appendix J, Option A, as The acceptance criteria for air lock testing are: modified by approved
- a. Overall air lock leakage rate is s 0.05 L, exemptions when tested at 2 P,.
- b. For each door, leakage rate is < 0.01 L, when tested at 2 14.68 psig.
SR 3.6.2.2 Perform a pressure test on each inflatable air 6 months lock door seal and verify door seal leakage is
< 15 sccm.
1
l l l Containment Air Locks B 3.6.2 l BASES (continued) APPLICABLE The DBAs that result in a release of radioactive material SAFETY ANALYSES within containment are a loss of coolant accident and a rod ejection accident (Ref. 2). In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of
,e 0.3% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50 Appendix J (Ref.1),
[ Q*q sa4o,3o), . 0- as1'the maximum allowable containment leakage rate at the (% 3 g 0 ,y h following a DBA. calculated peak This allowable containment leakage internal rate forms the pressure P, = 14 basis for the acceptance criteria imposed on the SRs associated with the air locks. The containment air locks satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3). LC0 Each containment air lock forms part of the containment pressure boundary. As part of the containment pressure l', boundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPEKABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock I door of an air lock to be opened at one time. This 1 provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into or exit from containment. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the A (continued) U McGuire Unit 1 B 3.6-7 N 5/20/.9L
Containment Air Locks B 3.6.2 BASES (continued) SURVEILLANCE SR 3.6.2.1 REQUIREMENTS __ he.pna Arpe,,g Maintaining containment air locks OPERABLE requires compliance with th_e leakage rate test _ requirements of @ OP M M ds 65
-MEontemment temrae Rate ie.mno ermens. This SR reflects N'd'1'J b *tfM the leakage rate testing requirements with regard to air ,O'
- lock leakage (Type B leakage tests). The acceptance riteria were established during initial air lock and Ark.hw 4g &'OgL M.){ ontainment OPERABILITY testing. The periodic testing f *'3 equirements verify that the air lock leakage does not h*4".
T > T % R I.o.2. 5 exceed the allowed fraction of the overall con ainment L I ) [.hf3.Jeakagerate. I The Freauency is required by axaus-rata Tas tf-g omr?. emnta4Wnest
, neat l The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful perfonnance of the overall air lock leakage test.
This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1. This ensures that air O V lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate. SR 3.6.2.2D The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not nonnally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be perfonned p (continued) b McGuire Unit 1 B 3.6-12 En/ki 2- 5/20/9P
1 o INSERT 1 The frequency required by 10 CFR 50 Appendix J, Option A, includes leak testing each door seal within 72 hours of closing or every 72 hours t hen entries are being made more frequently. The seal annulus leakage must be < 0.01 L as determined by precision flow measurements when measured for at least 30 seconds with the pressure between the seals t P. Overall airlock leakage tests are conducted at P every 6 months. Tbe overall air lock leakage rate must also be verifi,ed prior to establishing containment OPERABILITY following maintenance on the air lock which could affect the air lock sealing capability. This is an exemption from 10 CFR 50, Appendix J, Option A. INSERT 2 SR 3.6.2.2 Door seals must be tested every 6 months to verify the integrity of the inflatable door seal. The measured leakage rate must be less than 15 standard cubic centimeters per minute (sccm) per door seal when the seal is inflated to approximately 85 psig. This ensures that the seals will O remain inflated for at least 7 days should the instrument air supply to the seals be lost. The Frequency of testing is consistent with the overall airlock leakage tests required every 6 months by 10 CFR 50, Appendix J Option A (Ref. 1). INSERT Page B 3.6-12 f l
Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2. (continued) REQUIREMENTS every 18 months. The 18 month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage, and the potential for loss of (g gma( pyQ containment OPERABILITY if the surveillance were performed [ [ I with the reactor at power.f The Frequency is based on a lagg g j engineering judgment and is considered adequate given that J W E 'e k d *" 5'at"' the interlock is not challenged during the use of the Maj U/fMd" interlock. REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(11).
I O McGuire Unit 1 B 3.6-13 .K l ff em.J-W
I Containment Air Locks B 3.6.2 O BASES (continued) i APPLICABLE The DBAs that result in a release of radioactive naterial ' SAFETY ANALYSES within containment are a loss of coolant accident and a rod ejection accident (Ref. 2). In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The , containment was designed with an allowable leakage rate of 0.3% of containment air weight per day (Ref. 2). This ; ( o.36 % 4 leakage rate is defined in 10 CFR 50, Appendix J (Ref.1), ' gg gjthe maximum allowable containment leakage rate at the 1 calculated peak containment internal pressure P, = 14.8 psig ' MMF
/ following a DBA. This allowable leakage rate forms the J basis for the acceptance criteria imposed on the SRs associated with the air locks.
The containment air locks satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3). LCO Each containment air lock forms part of the containment pressure boundary. As part of the containment pressure '
\
boundary, the air lock safety function is related to control s of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type 8 air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock , is not being used for nonnal entry into or exit from j containment. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the (continued) McGuire Unit 2 B 3.6-7 Lpf6ML SW ! l
Containment Air Locks B 3.6.2
~
BASES (continued) l l i SURVEILLANCE SR 3.6.2 1 REQUI_REMENT() 5AsjiJ, Maintaining containment air locks OPERABLE requires i ofw A (.ner.0, a compu ance w g p e page rate test mqu w menu o @ l =vman -
--c n = m vrmura. This SR reflects m.KJj a Aab #"3% the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance (AppJJ, E. A W.f), criteria were established during initial air lock and 49 containment OPERABILITY testing. The periodic testing ew.py.e. ,bg)e,wt requirements verify that the air lock leakage does not 8
exceed the allowed fraction of the overall containment O.M * * "M'~ M T ") leakage rate. The Frequency is required by che w ain M eakage-Rate Testing Proarxts. cri . g he SR Thas been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful perfonnance of the overall air lock leakage test. ; This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event l of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1. This ensures that air ' lock leakage is properly accounted for in detennining the Os combined Type B and C containment leakage rate. l _SR 3.6.2.M The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accidant containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock ! will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when ' the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed (continued) McGuire Unit 2 B 3.6-12 M/U ' -4/20/9f-
INSERT 1 The frequency required by 10 CFR 50 Appendix J, Option A, includes leak testing each door seal within 72 hours of closing or every 72 hours when entries are being made more frequently. The seal annulus leakage must be < 0.01 L as determined by precision flow measurements when measured for at least 30 seconds with the pressure between the seals t P. Overall airlock leakage tests are conducted at P every 6 months. Tbe overall air lock leakage rate must also be verifi'ed prior to establishing containment OPERABILITY following maintenance on the air lock which could affect the air lock sealing capability. This is an exemption from 10 CFR 50, Appendix J, Option A. INSERT 2 SR 3.6.2.2 Door seals must be tested every 6 months to verify the integrity of the inflatable door seal. The measured leakage rate must be less than 15 standard cubic centimeters per minute (sccm) per door seal when the seal is inflated to approximately 85 psig. This ensures that the seals will O remain inflated for at least 7 days should the instrument air supply to the seals be lost. The Frequency of testing is consistent with the overall airlock leakage tests required every 6 months by 10 CFR 50, Appendix J, Option A (Ref. 1). !~ INSERT Page B 3.6-12
Centainment Air Lecks B 3.6.2 , BASES SURVEILLANCE SR 3.6.2 (continued) REQUIREMENTS every 18 months. The 18 month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the surveillance were perfonned hlF-4
,C,. W 6 Frey9 p ,l J . [3) with the reactor at powerg The Frequency is based on J u sH A M 6/ ., y,, yg, engineering Juagment and is considered adequate given that f opk U N"'"' the interlock is not challenged during the use of the Q j interlock.
REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.36. Technical Specifications, (c)(2)(ii).
O O McGuire Unit 2 8 3.6-13 & fpf m d b o/zu/F/'
S/< <<dr n dee., L & . 2. O (@@ CONTAINMDIT. SYSTEMS CONTAlfelENT AIR LOCKS j LIMITING CONDITION FOR OPERATTON LCS W1 @ tainment air loc hall be OPERA 8LE diH 8t 44 1
. Both rs closed except when air lock is being ig(ed for norma tr t entry and exits th h the containment, thp6 a+ 1===+ one i lock door shall be c1 . and I I S 3 k al all air lock leakage rate of less than 0.05 L at P.,14 ee s APPLICABILITY: NODES 1, 2, 3, and 4.
A TW: (das w ane_ con /mnonro<tos H n h . g@ @ 1 pith one con s t air 1 e inoperable: aar A,1O intsin at le he OPERA 8LE air lock door closed a 4,7 < +4 4. 4 - - a u _- _ _ _ - q- x x__w . . 6 n Q fxu.A.15 24 hours diock the OPERABLE air lock door closed, l g lhq Jpe on may 6nen co m red everm11-air
~nue unua perro k'leaka test nce or use vided tha ne OPERABLE air lock door isTerif ad to 1(4 locked closed at least Q p/- A once per 31 days, O Actsav 8 Otherwise, be in at least HOT STAfe8Y within the next 6 hours and in COLD SHLITDOWN within the following 30 hours, and yt
- 9. me nrovistaa< d saecificatien Lo a are not annitcab p g,-
AcnniC.- -t3b With the..containment airm lock inoperable,[t one air lock door w4en
<r 5 u- - -- m r m L ___. ecaim t leas clos rtstore the inoperable air ock to OPERABLE status within 24 h r be in at least NOT STANDS ithin the next 6 hours and in Armcu s O COLD within the following hours.
k G/,de g,,n f,] g cudde o. mil i M cadminuwd 4c
*IC- fer Lf.O S.4,l tm,,,,j,J,(Y' 1
McGUIRE - UNIT 1 3/4 6-5 Amendment No. 166 i Pay s I c f $ (
.5.fo.2, 6)Vcekcadus's CONTAINMOIT SYSTEMS .
l O [6,2. Coodmh meni &r [ f$URVElsf aarr affluit M kR '54.b j I
$ J4,2.1 M3 raen sanFaisimmasit air itek ch=11 h dd noream raa a- +->+.d 3 (mfeeT 5 fa . Within 72 hours allowing each closing, except when tryf being used for 1ticle entries, then at least once per r lock i 2 hours, b
[ verifying the the seal leakaee is less than 0,01 L.la detefairod
}
by precision low seasurements when seasured for at ast 30 seconds with the yo between the seals at a constant pre sure of 14.8 psig,
- b. By c ting overall air lock leakage tests a not less than P 14.8 p g, and verifying the overall air loc eakagerateiswT, thin its 1 it:
- 4. 5
~
- 1) At least once per 6 months, # and
- 4. Prior to establishing CONTAINNENT TEGRITY when maintenance has been performed on the air loc that could affect the air ~,
'I lock seallne capability.*
l g 3,4, .c At least once perle sonths by verifying that only one door in air lock can be opened at a time, and
- d. At least per 6 months by cond ing a pressure te to vertr N door seal tegrity, with a measu leak rate of le han 5 sta cubic centimeters pe minute f
~
@The provitians if Specification 44.2 are not anpMcab l
QTh)( constitutes J6 exemption to AWix J of 10frR w u,3 l McGUIRE - IMIT 1 3/4 6-6 Anemheent No. 166 hqc 4ofb 1 l 1
Specification 3.6. 2__ Insert 5 A.9 SURVEILLANCE REQUIREMENTS
]
1 SURVEILLANCE FREQUENCY l SR 3.6.2.1 ------------------NOTES--------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in ------NOTE----- I accordance with 10 CFR 50, Appendix J, SR 3.0.2 is not Option A, as modified by approved applicable.
exemptions. --------------- (\ Perform required air lock leakage rate In accordance \ testing in accordance with10 CFR 50, with 10 CFR 50, Appendix J, Option A, as modified by Appendix J, approved exemptions. Optton A, as modified by The acceptance criteria for air lock opproved testing are: exemptions
- a. OveralI air lock leakage rate is < 0.05 La when tested at t Pa
- b. For each door, leakage rate is <
0.01 La when tested at t 14.8 psig. l l McGuire l Page $ of 5 !
6}%*bdA.bt0m 3. Q [y,4 CONTAllBENT SYSTDtS y,yy, f0NTAIREff AIR LOCKS O ,hlI I'INITIEi CWEITION FOR OPGtATION l LC 0 %.1. I"~
- 6ED)(a2R tainment air loc' shall be OPDIABLE@
. sota rs closed except when or air lock is beine used for Jir imeT) . t t entry and exits th the costalanent, then at least ent/
I lock door shall be el and /
'b'l* air lock leakage rate of less than 0.05 L. at P.,
ee APPLICABILITY: MODES 1, 2, 3, and 4. m: G or ore. em4me o,w, 4- Att leeks) Aerim A e fdith onegainment air lock le: b'" / M furr[ d.,,tb gaytfie
. * ]3esh at' OPDIABLE
-r--_-_-- air lock door closedend @
---------------n A 2-24 rs\a(lock the OPGtAOLE air leck door closed. d.i
_-- . d c.11I'mM eek e L. OPDIABLE once per 31 days, air lock door isbrH ocked closed atdleast
*M[DO+Y
,g 4)_ )
'Acnen 8 AcmW D SB Othenrise, be la at least NOT STAND 8Y within the next 6 hours and in COLD $HilTD0l01 within the following 30 hours, and O m..._..._._,-a.....___ -
-.. m4D z Acreen c. O .Withi the =u contalanent m- .e. air. lock
- inoperable
===-e= at least [svumpf-wrterwtutr one air lock door ann mg, c1 restore the inoperable air lock to OPDIAgLE states within 24 g.rw p hos or be la at least NOT ST withis the next 6 hours and in
- COLD within the following hours.
Mhuhone. Law) VS Tarkds ubek n (fo wtale. swu// codahment %c yg}c,, for LCD 3do./ - i w taaleigi 04 McGUIRE - UN!' T 2 3/4 6-5 Amendment No. 148 j l 1 lO 1 Qc lof.S
I Sps&adran 3.62 CONTAllBEIIT SYSTEMS g2 %i,menf A<< lekh
.o u -
~
(5a.5J,.t.l ! 8 0, a ..r ; '- -- " - r - - ' n' - ---' n 9 p;9 J,G.2,1 -
- a. Within 72 hours llowing each closing, except when t ock s 4MM I being used for 1ticle untries. then at leasteronceAs/ 7 hou air g verifying that by precision seal ' eakaee is less than c.01 LMs ou measurements when measured for atles termined 30 seconds with the vol between the seals at a constant press of 14.8 psig,
- b. sy ing overall air lock leakage tests at no less than p 14.8 psi , and verifying the overall air lock lea gerateiswT, thin )
its 11 : l least once per 6 months, # and M<3 l 1) ,
- 2) Prior to establishing CONTAIISIElli ! ITY when maintenance
// has been performed on the air lock t could affect the air lock sealing capability.* _
$4 34 2,de At least once pede months by veri og that only one door in dElp air lock can be opened at a time, At least 6 months by conducti pressure test to veriff)
SE %.M door seal ty, with a measured I rate of less thagn 5 standa e centimeters per at .f O
" d .
fTE prwist of Specification .0.2 are not appli e7 itstes an exemption Appendix J ef 10 50 ) (*This ficGUlltE - tMIT'1 3/4 6-6 Amenahment slo. 148 l O Pne a o:S 1
i i Specification 3.6.1-Insert 5 49 SURVEILLANCE REQUIREMENTS SURVEILLANCE l FREQUENCY SR 3.6.2.1 ------------------NOTES-------------------- l
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in ------NOTE-----
accordance with 10 CFR 50, Appendix J, SR 3.0.2 is not Option A, as modified by approved applicable. exemptions. --------------- l / Perform required air lock leakage rate In accordance testing in accordance with10 CFR 50, with 10 CFR 50, Appendix J, Option A, as modified by Appendix J, approved exemptions. Option A, as modified by The acceptance criteria for air lock approved i testing are: exempttons
- a. Overall air lock leakage rate is < 0.05 La when tested at z Pa-
- b. For each door, leakage rate is <
0.01 La when tested at t 14.8 psig. McGuire 'L Page J of p
Discussien of Chang:s Section 3.6 - Centainment Systems n ADMINISTRATIVE CHANGES (] A.8 CTS 3.6.1.3 Action a.4, providing an exception to CTS Specification 3.0.4 is deleted. This exception is no longer required because the Actions retained in ITS 3.6.2 allow continued operation for an unlimited period of time. LCO 3.0.4 does not allow MODE changes when the LC0 is not met, unless an exception to LC0 3.0.4 is specified or if the actions to be entered allow continued operation in the MODE or other specified condition in I the Applicability for an unlimited period of time. This change is j administrative because no technical requirements have been changed. This change is consistent with NUREG-1431. 1 A.9 The specific details of CTS Surveillance 4.6.1.3.a and b are replaced by a more general requirement to perform airlock leak rate testing as required by 10 CFR 50 Appendix J, Option A,%e Centainment Leakage Rate Test Program and two Notes. The Notes are added to remind the user that: 1) an inoperable door does not invalidate a s_uccessful performance of an overall air lock leakage rate test, and 2) results of air lock testing will be evaluated for impact on overalT containment leakage rate requirements. The remaining portions of the surveillance are relocated to the O BasesCcatainmentLeakageRateTestingProgramandareaddressedbyl a removal of detail change later in this section. No technical requirements are modified by these changes and they are considered administrative in nature. These changes are consistent with NUREG-1431 and the "C guidance on the implementation fer 10 CFR 50, Appendix J. Option B. A.10 Four Notes are added to the Actions for CTS 3.6.3, " Containment Isolation Valves". Notes 1, 3, and 4 provide guidance and clarification for the use of the TS. Note 1 allows for intermittent unisolation of an inoperable penetration flow path (s) under administrative controls consistent with CTS 4.6.1.1.a (see DOC L.31 for associated iess restrictive changes). This is allowed for all penetration flow paths except containment purge valves for the lower compartment and instrument room. Note 3 requires the entry into the applicable Conditions and Required Actions for systems made inoperable by an inoperable containment isolation valve. Note 4 requires the applicable Condition and Required Action of LC0 3.6.1, " Containment," to be evaluated, when an isolation valve leakage rate results in exceeding the overall containment leakage rate. These two notes avoid misinterpretation () (s of the TS. No technical requirements are altered by these McGuire Units 1 and 2 Page A - 3M Supplement 25/20/97l
piscussian of Ching2s SIcticn 3.6 - Centainment Systems l TECHNICAL CHANGES - REMOVAL OF DETAILS LA.1 CTS Surveillance Requirements 4.5.1.1.c, 4.6.1.2.c, 4.5.1.2.d.2, 4.6.1.2.d.4, 4.5.1.2.h, 4.6.1.2.1, and 4.6.1.6 contain details and exemptions for meeting the leak rate testing requirements stated in 10 CFR 50, Appendix J, Option B for Type A testing. ITS SR 3.6.1.1 contains the broader requirement that all applicable Type A testing and inspectfon specified by 10 CFR 50, Appendix J, Optfon B must be met, except for the containnent air 1cck:. ITS l 3.6.2 includes the requirements for the containment air locks ~ { The specific acceptance criteria for Type A leakage rate testing l l are retained in ITS 5.5.2. The details of how the requirements of 10 CFR 50 Appendix J, Option 8 are met are relocated to the l Containment Leakage Rate Testing Program. Approved exemptions are I not necessary for inclusion within the TS. Changes to this program I will be evaluated under the site procedure control program to ensure compliance with the CFR and approved exemptions. This change is consistent with the NUREG-1431 philosophy of relocating certain details outside of the TS. LA.2 The descriptive information in the CTS LC0 3.6.1.3.a. regarding OPERABILITY of the air locks, is being moved to the Bases for ITS O 3.6.2. The novement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate for the Bases. The Bases are subject to the controls described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change in ITS 3.6.2 is consistent with NUREG-1431. I l LA.3 CTS Surveillances 4.6.1.3.a and b contain detailed information ) describing the airlock testing required by 10 CFR 50, Appendix J. ! This descriptive information is moved to the Bases and replaced 1 with the ITS SR 3.6.2.1 which references 10 CFR 50, Appendix J, Option Athe Containment Leakage P, ate-Te: ting Program. The frequency of testing is required by 10 CFR 50, Appendix J, Optfon A and the acceptance criteria are retained in ITS SR 3.6.2.15r54. Other detail information contained in the CTS Surveillance, including any exemptions to 10 CFR 50, Appendix J, is relocated to the Basesf4 :nt procedurc; implementing the requirements. The l l movement of this information is appropriate because it involves l details that are not necessary for inclusion in the LCOs and are more appropriate for the Basesplant precedures. Any changes to these Basesdccument+ are controlled by the Basesprocedure control f I McGuire Units 1 and 2 Page LA - 1 Supplement 26/24/97l
i I l Discussien cf Changes I S:cticn 3.6 - Centainment Systems l TECHNICAL CHANGES - REMOVAL OF DETAILS program required by ITS 5.0, Administrative Controls. Anychange,l l using this criteria, will ensure proper review and conformance to the requirements of 10 CFR 50, Appendix J. This change is consistent with NUREG-1431-and the NRC mcdch for the imp?cmentatica of 10 CFR 50, Appendix J Option;. LA.4 CTS Surveillance 4.6.1.3.d contains detail information concerning the pneumatic seal system for the personnel air lock doors. Testing of airlock door seals is required by 10 CFR 50, Appendix J, Option A. The detail information contained in the CTS l Surveillance, including any exemptions to 10 CFR 50, Appendix J, is relocated to the Bases for ITS 3.6.2 Containment Leakage St+ Tc'. ting Program. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate for the Basesp hnt program; and procedure;. Any changes to these Basesdccument+ are evaluated under the Basesprocedure control program required by ITS 5.0, Administrative Controls. ITS SR 3.6.2.1 requires that airlock testing be conducted in accordance with 10 CFR 50, Appendix J, Option A and the Conta4nment Leakage Stc Tc; ting Progrr. !TS t f.5.2 provides the acceptance criteria cnd minim = requirement; for inck;ien in the program, inc'uding confc = nce with 10 CFR 50, Appendix J. This change is consistent with NUREG-1431. LA.5 CTS 4.6.3.1 Surveillance Requirement requires an operability l verification for each containment isolation valve prior to returning the valve to service after maintenance, repair or replacement work on the valve or its associated actuator, or control or power circuit. These details describing when an SR is required to be performed is more appropriate for plant procedures. Moving this information to procedures is not an impact on the public health and safety because it only relocates administrative direction that is implicit in the QA Program controls associated with the maintenance process. Any changes to the procedures are evaluated under the procedure control program. Any change, using this criteria, will ensure proper review and conformance to the QA Program requirements. This change is consistent with NUREG-1431. LA.6 The descriptive material contained in the CTS 4.6.3.2 regarding the details of which test signal (Phase A, Phase B, or Safety i Injection) should be applied to isolation valve testing is moved to the Bases for ITS 3.6.3. The Containment Radioactivity-High McGuire Units 1 and 2 Page LA - 2 Supplement 25/44/47 l l 1
l Discussicn of Chtnges 52cticn 3.6 - Centainment Systems TECHNICAL CHANGES - REMOVAL OF DETAILS signal to close the purge and exhaust valves is not moved to the Bases.because it is not credited in the accident analysis and is only used for effluent control. However, the Safety Injection signal closure of the purge valves is discussed because it is credited in the accident analysis for this function. This type of detail only provides information that would not normally have to be specifically clarified. Moving the detail to the Bases is appropriate and provides adequate protection for the health and safety of the public. The Bases are subject to the controls described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.7 Not used. LA.8 CTS 4.6.1.5.1, 4.6.1.5.2, and the associated foot note contain descriptive information on measurement locations and on how the average containment temperature is weighted. This information is w moved to the Bases for ITS 3.6.5. The methods for calculating average temperature is a detail not necessary for inclusion within the TS. The Bases are subject to the controls described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.9 Descriptive information regarding system operability and independence in CTS 3.6.2 and 4.6.2 is moved to the ITS 3.5.6 Bases. The movement of this information is appropriate because it involves details that are not necessary for inclusion within the TS. The controls specified in ITS LC0 3.6.6 ensure the safety and health of the public are protected. The Bases are subject to the controls described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.10 Descriptive infonaation in CTS 3.6.4.2 regarding the hydrogen recombiner is moved to the ITS 3.6.7 Bases. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more appropriate McGuire Units 1 and 2 Page LA - 3 Supplement 25/20/97l
0 - Contairnent Air Locks W-=heric. l _
%* erie Ice condenser. ano3.6.2 mau @
l l SUR'KILLANCE REQUIRDOTS SURVEILLANCE FREQUENCY SR 3.6.2.1 ------------- NOTES---------- - - -
- 1. An inoperable air lock door does rot invalidate the previous successful .A /
perfonnance of the overall air lockj#R - leakage test.
^
/C' M s - q C
- 2. Results shall be evaluated agairyg acceptance criters SR 3.6.1 m U7- /T h , ------
a r Per onn required air lock bleakaoe rate -- ----- 1 7 testinginaccordancewith)juLtM'g SR .0.2 is t ~%p
@penau , as mou_m eu vy approved a 1 cable
'exerrpti s. 3 g, p g -------
l "N*- --s'The a gtance crite a for air loc , In accordance 1 testi g are: withj Lt K p g*[$ f ix J. a g@I ! p a. Overall s [0.05 L.) air 1 ek leakapat teste ra is P,. ed l op u ,
. Fr ch or, leakage r e is O "
s 6 o.o1
. L, tested a >Afvpsia .
M ,
~
SR 3.6.2[f --------- ta --NOTE-- - E---- -2 l Only requi be perfo upon ent or' g ,--Q exit the the contai t air loc . - sr A m - _- - .---------- -- ----- ---.---
)( lo Verify only one door in the air lock can be opened at a time.
WG STS 3.6-7 Rev 1, 04/07/95 p C hstila o
1 INSERT SR 3.6.2.2 Perform a pressure test on each inflatable air lock door seal and 6 months verify door seal leakage is < 15 sccm. l I i i O i INSERT Page 3.6-7 O i
i O. Containment Air Locks THharir mat =n-P "- inndano r ~5 n .a g Q,2, B 3.6.2 BASES (continued) APPLICABLE The DBAs that result in a release of radioactive seterial SAFETYANALYSES within containment are a loss of coolant accident and a rod ejection accident (Ref. 2). In the analysis of ea6 of these accidents, it is assumed that containment is OPERABLE 4 such that release of fission products to the envirorument is The 3% controlled contatronentbywas the designed rate of containment leaka$e. with an allowable eakage rate of G of contairveent air weight per day .(Ref. 2). This l==6ana.cair is defined in 10 CFR 50. Appendix J (Ref.1), A 3my ati or ngv. a ot/contairvent airn eiant nar m the J g iam aTiowa6le containment leaka rate at the calculeted peak contairinent internal ressure = (14. sig ) following a DBA. This all able les age rate onns the basis for the acceptance criteria isposed on the SRs associated with the air locks. Q The containment air locks satisfy Criterion 3 oft 1EP1BB a crg, p, sp) twiev ramnens. (g py [hthe< &amadd@ LC0 Each containment air lock forms part of the tairunent pressure boundary. As part of containmen the air lock ( safety function is related to control of - contairveent leakage rate resulting from a DBA. Thus, ea d air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE. the air lock interlock mechanism sust be OPERABLE, the air lock must be in cospliance with the Type B air lock leakage test, and both air lock doors sust be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak ti t barrier following postulated events. N. evertheless, bo doors are kept closed when the air lock is not being used for nonnal entry into GER exit from contairinent. Q APPLICABILITY In MODES 1, 2. 3, and 4, a DBA could cause a release of radioactive material to containment. In N0 DES S and 6, the (contirued) l WOG STS B 3.6-22 Rev 1. 04/07/95 N Std-c,
i O-Containment Air Locks B 3.6.2 l BASES (continued) y
^
Se\d hw SINIVEILLAICE SR 1.6.2.1 y. 8l kbf REQUIREMENTS Maintaining containment air locks OPERABLE recpires i compliance with the akage rate test requirements of a Np .--- M " "'- bel MD g U y K DUM=1 C This SR reflects the lenka rate testing requ'irements with regard to air lock 1 e (Type B leakage tests). The acceptance criteria were es lished dJring initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock _ leakage does not exceed the allowed fraction of the overall containeerit leakage rate. h Frequency is required by hb. h ** filopendix MRe y . U as sivumec qhus. SR :;.0 I fuhich allows F y approveo ex g vi.. m sanev extensionsydoes nofje gy- g h Q.sstM.T) The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful perfonnance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event f,a ,g, of a DBA. Note 2 has been added to this SR requiring the O M g g,le_, 6, y resultstobeevaluatedagainsttheacceptancecriteria@ SR 3.6.1.1. This ensures that air lock leakage is proper,y eccounted for in detenmining the eGMiB containment leakage g g"" 4 , s.a,.,a r.,y. a a p _ l l SR 3.6.2 M h The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the 1 inner and outer doors of an air lock are designed to , withstand the maximus expected post accident containment l sure closure of either door will support containment r ILITY. Thus, the door interlock feature sgports h containmentOPERABILITYwhiletheairlockisbei%u persomel transit in and out of the containment. testing of this interlock demonstratas that the interlock riodic e l will function as designed and that simultaneous opening of ,
% ervn.U d the inner and outer doors will not inadvertently occur. Due i to the ourely mechanical nature of _this interlock, and given ust ++, e4 . snet the interlock mechanism isesTy.) challenged when the W.Mynee4=afr W enntairunent air lock door isMRElllh this test is only )
.g, _
NN = k- _ (continued) I . .. W STS 1 - 8 3.6- L Rev 1. 04/07/95 (.isessery if % Rs. m it ~ R~r. s-.im (y,6,g } u . + ,,a 4. ,A - w; y g dwL O wa/er 4 4 c= 2. W fl f apply 4c4*l4elos.fopl.J-49 %J H4 p g , y on.no,un1Ane f*"' se w ,na e Ibt I8.**aD4w s1 f A keiAint 4 JJa,J > If 0 '" $pt a pp,.fgd/ M O % ( re M 2Ye%. _
! INSERT 1 i O @ l l The frequency required by 10 CFR 50 Appendix J, Option A, includes leak i testing each door seal within 72 hours of closing or every 72 hours when i entries are being made more frequently. The seal annulus leakage must be i
< 0.01 L, as determined by precision flow measurements when measured for at i least 30 seconds with the pressure between the seals > P,. Overall airlock i leakage tests are conducted at P every 6 months. The overall air lock I leakage rate must also be verified prior to establishing containment i OPERABILITY. If the periodic 6-month test required Appendix J, Option A, is I current, the seal leakage test may be substituted for the full pressure test i provided no maintenance has been performed on an air lock. Whenever i maintenance has been performed on an air lock, the requirements of paragraph l III.D.2(b)(ii) of Appendix J, Option A must still be met. This is an i exemption from 10 CFR 50, Appendix J, Option A. I INSERT 2 SR 3.6.2.2 Door seals must be tested every 6 months to verify the integrity of the inflatable door seal. The measured leakage rate must be less than 15 standard cubic centimeters per minute (sccm) per door seal when the seal is inflated to O approximately 85 psig. This ensures that the seals will remain inflated for at least 7 days should the instrument air supply to the seals be lost. The Frequency of testing is consistent with the overall airlock leakage tests required every 6 months by 10 CFR 50, Appendix J. Option A (Ref. 1).
INSERT Page B 3.6-27 1
Programs and Manuals i 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Mar uls The following programs shall be established, implemented, and maintained. 5.5.1 Offsite Dose Calculation Manual (0DCM1 The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program. Licensee initiated changes to the ODCM:
- a. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
- 1. sufficient information to support the change (s) together with the appropriate analyses or evaluations justifying the change (s), and
- 2. a determination that the change (s) do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;
- b. Shall ber.ome effective after the approval of the Station Manager; and
- c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent l with the Radioactive Effluent Release Report for the period '
of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented. 5.5.2 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, for Type A testing, as modified by l 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. l (continued) O McGuire Unit 1 5.0-7 Supplement 2 l
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.2 Containment Leakaoe Rate Testino Prooram (continued) The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 14.8 psig. The maximum allowable containment leakage rate, La, at Pa, shall be 0.3% of containment air weight per day. l Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 La.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 La for Type A tests. The provisions of SP 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. 5.5.3 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly ( radioactive fluids during a serious transient or accident to i levels as low as practicable. The systems include Containment ! Spray, Safety Injection, Chemical and Volume Control, Nuclear Sampling, RHR, Boron Recycle, Refueling Water, Liquid Waste, and Waste Gas. The program shall include the following:
- a. Preventive maintenance and periodic visual inspection requirements; and
- b. Integrated leak test requirements for each system at refueling cycle intervals or less.
(conthued) O 5.0-8 Supplement 2 l McGuire Unit 1
Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS O l 5.5 Programs and Manuals I The following prc' grams shall be established, implemented, and maintained. 5.5.1 Offsite Dose Calculation Manual (0DCM) The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program. Licensee initiated changes to the ODCM:
- a. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
- 1. sufficient information to support the change (s) together with the appropriate analyses or evaluations justifying the change (s), and
- 2. a determination that the change (s) do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;
- b. Shall become effective after the approval of the Station Manager; and
- c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent !
with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. l Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month ; and year) the change was implemented, i 5.5.2 [pntainment 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, for Type A testing, as modified by l 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. (continued) O McGuire Unit 2 5.0-7 Supplement 2 l
Programs and Manuals ) 5.5 5.5 Programs and Manuals O 5.5.2 Containment Leakaae Rate Testino Proaram (continued) The peak calculated containment internal pressure for the design l basis loss of coolant accident, Pa, is 14.8 psig. The maximum allowable containment leakage rate, La, at Pa, shall be 0.3% of l containment air weight per day.
- Leakage Rate acceptance criteria are:
l
- a. Containment leakage rate acceptance criterion is s 1.0 La.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 La for Type A tests. The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. ) l The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. l l 5.5.3 Primary Coolant Sources Outside Containment i This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include Containment Spray, Safety Injection, Chemical and Volume Control, Nuclear Sampling, RHR, Boron Recycle, Refueling Water, Liquid Waste, and Waste Gas. The program shall include the following:
- a. Preventive maintenance and periodic visual inspection requirements; and
- b. Integrated leak test requirements for each system at refueling cycle intervals or less.
(continued) O l McGuire Unit 2 5.0-8 Supplement 2
Specification 5.5.2 INSERT 4 r 5.5.2 Containment Leakage Rate Testing Program 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, for Type A testing, as modified by approved l exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Perfonnance-Based Containment Leak-Test Program," dated September 1995. The peak calculated containment intemal pressure for the design basis loss of coolant accident, P., is 14.8 psig. The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are: l a. Containment leakage rate acceptance criterion is s 1.0 L.. During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.75 L. for Type A tests. The provisions of SR 3.0.2 do not apply to the test frequencies specified
"(q y in the Containment Leakage Rate Testing Program.
The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. l i l
\
l Q . McGuire l Page l'l of (,9
5 M <,es w k lA5h b A
'1. c w h e.,.t 6 - N r hi c.
, ONTAll0ENT SYSTEMD 5'. C ~2.
CONTAlletENT LFAKACE i S w t-f ' D N' ~ LIMITING CONDITION FOR OPERAT d 6.1.2 Containment leakage rates shall be Ifmited tod N sacludeL @ An overall integrated leakage rate of less than or equal to L ,
$ Ys'.Y g weight of the containment air per 24 hours at P ,
l 3@ in . i a J @ [A cos6fned leakage rate of less than 0.60 L for all penetrations
. . . / %andvalvessubjecttoTypeBandCtr.sts, d en pressurized to P.,
- c. A combined bypass leakage rate of less than 0.07 L for all penetra-( % ,g tions identified as secondary containment bypass 1 akage paths when pressurized to P,.
g APPtICARILfTY: MODES I, 2, 3, and 4.* ACIlgg: l
,Md .b ,
5.I. 2. A With (a) the measured overall f at*arat.11Lc_ontainment 1eakaos rate exceeding 0.75 L or (WYhe measured combined leakage rate for all
% valves ~sub_iecttoTypesBandCtestsexceedina0.60L., Wauons ana~
gu = Qypassleakage rate excecoing u.ui L,; Restore the overaTI integrafea leattci tne combined N 3 l
@rato_less than 0.75 L, and the combined _Jieaki pg ,1,.
g! "' and valves subject to Type B and c tests ~to less$e rate iur aii penetrations combinee oy ass leakage rate to less snan v.ui L than 0.60 L.,fano the 1 Reactor Coo ant System temperature above 200*F. ,fprior to increasing the i g= g O v 'Y 'gjg 6 SURVEILLANCE REQUIREMENTS
.1.
I g, 4 1 Type A containment leakage rates shall be demonstrated as required by r, .54(o) and Appendix J of 10 CFR 50, Option B, as modified by approved September, 1995. exemptions, and in accordance with the guidelines of Regulatory 7 o sne-time change is granted to have the containment purge supply and/or exhaust isolation valves for the upper and lower compartment open in Modes 5" **'"-f 3 and 4 following the steam generator replacement outage. The cumulative time , 4.<IT3 3.l. l ~for having days. the valves open in Modes 3 and 4 is limited to fourteen (14) All other provisions of this specification apply with the exception of those containment purge valves open in Modes 3 and 4. Each valve will be sealed closed prior to initial entry into Mode 2. j
]
McGUIRE - UNIT 1 3/4 6-2 Amendment No.174 y 174 #/ 41
I , Q u w ,'
~
s.s.2 INMENT SYST k SURVEILLAMCE REOUIREMENTS (Continued) . N" a. Deleted
& LT3 3.(..f/
- b. Deleted (. l
~. c. l The accuracy of each Type A test shall be verified by a supplemental test in accordance with Regulatory Guide 1.163, September,1995.
.I
' y' l \ Type 8 and C tests shall be conducted, in accordance with 10 CFR N
, "g ' ' # @ (50.54(o) 14.8 and 10 CFR 50 Appendix J. Option A < l vol ig, at intervals no greater than 24 months except for tests hgt
- 1) Air locks,
- 2) Dual ply bellows assembifes on containment penetrations between the containment building and the annulus, and ;
- 3) Purge supply and exhaust isolation valves with resfifent material seals. k
.Sem.< y t '
fre .7T5 1.6.1 4) Type C tests performed on containment penetrations H372 H373 without draining the g1 col-water mixture from the seats of ! their diaphragm valves NF-228A, NF-2338, and NF-234A , if meetin l ernr)g a zero indicated leakage rate (not including i )nstrum for the di hrage valves. These tests may be used in lieu of tests whi are otherwise required by Section III.C.2(a) of 10 CFR 50, Appendix J to use air or nitrogen as 3 0. l 1 < McGUIRE - INIIT 1 3/4 6-3 Amendment No.173 y 1b of bi 1 U l l
h e e.wrb ONTAINMENT SYSTEMS 1 CONTAINMfMT AIR LOCKS - O- LINITIN's CONDITION FOR OPERATION'
)
~
Gss @ 9 7 g.rs 7.l 3.6.1.3 Each containment air lock hall be OPERABLE with:
- a. Both doors closed except when the air lock is being used for normal transit entry and exits through the containment, then at least on afr Inek daar ch=11 he clotent and _
y l e i
% An overall air lock leakage rate of less than 0.05 L, at P.,14.8
, 2. , psig.
b PPLICABILITY: MODES 1,2,3,anG 6CTION:
- a. With one containment air lock door inoperable:
- 1. Maintain at least the OPERABLE. air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours or lock the OPERABLE air lock door closed.
- 2. Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be locked closed at least
, once per 31 days,
& J D 7.6. 3. Otherwise, be'in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours, and
- 4. The provisions of Specification 3.0.4 are not applicable.
. With the containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. . McGUIRE - UNIT 1 3/4 6-5 Amendment No. 166 1
f IAof$1 1
- Wwo ckTsa --
- f. I. "2.
h0NTAINNENTSYSTED 1 SURVEILLANCE REOUTREMENTS
.li.1.3 Each containment air lock shall be demonstrated OPERABLE:
I a. Within 72 hours following each closing, except when the air lock is I s g - being used for multiple entries, then at least once per 72 hours, by verifying that Enw. seal leakaae is less than 0.01 E3as determined 1
% by precision flow measurements when neasured for at least 30 seconds with the volume between the seals at a constant pressure of 14.8 psig,
- b. By conducting overall air lock leakage tests at not less than P,,
14.8 psig, and verifying the overall air lock leakage rate is within its limit:
- 1) At least once per 6 months, f and
- 2) Prior to establishing CONTAINNENT INTEGRITY when maintenance has been performed on the air lock that could affect the air lock sealing capability.* .
{
- c. At least once per 6 months by vertfying that only one door in each air lock can be opened at a time, and
- d. At least once per 6 months by conducting a pressure test to verify ggy door seal integrity, with a measured leak rate of less than qm g; 15 standard cubic centimeters per minute.
1 I O i
#The provisions of Specification 4.0.2 are not applicable.
*This constitutes an exemption to Appendix J of 10 CFR 50. ,
, McGUIRE - UNIT 1 M Amendment No. 166 O & ' '" # #
Sp::cification 5.5.2 INSERT 4 1 5.5.2 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of l the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, for Type A testing, as modified by approved l 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. The peak calculated containment intemal pressure for the design basis loss of coolant accident, P., is 14.8 psig. The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 L..
During the first plant startup following testing in accordance with this program, the leakage rate acceptance criteria are <0.75 L. l forType A tests I The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. O McGuire 2- Page Ilof b9
Q S,1 6en1a h m V / n ra a & c ~7*estrug & , Spos o seeAT*n-- \
$~(,2 i
'CONTAll0ENT SYSTEMS W CONTAIsetENT t W M E O* %
~
- 4,I n 1.4,I ,
LINITIIIC ColmiTION FOR OPERATION k 3.6.1.2 _ Containmentleakageratesshallbelimitedto:l. h pg ; \ pg@[ of 7. 5 . 2. @ [0.305 4*8 psig, by weight of the containment air per 2 I "- 8 **
@ A combined leakage rate of less than 0.60 L for all penetratio iF. and valves subject to Type 8 and C tests, wbn pressurized to and 1 d1MT,h i
r c. ( A combined bypass leakage rate of less than 0.07 L for all penetra-g tions identified pressurized to P,. as secondary containnent bypass litakage paths whe IselhM.l APPLICABlilTY: MODES 1, 2, 3. and a * (ACTION: I . l
'11 M a- With (a .
fsi.2 ^ n 75 t )org) Ene mess...e combined leaEafe rateSee** forh\ D. US l i\ bm,W
/ valyss~ subject to Types 8 and C tests are-edian c_sao Lthe
>ypass 10----- - orIc A f5 5.' 'l datato raw -- -ecing U.vi tidneru uw - J. . e
- ied ) *
=Wh.
.. . wg s e, .
tuo anl valves cousineo . subject to Type B and 0 tests to less than ons 0.60 N'/, L.Ja l (Reactor Cooiant system tesperature t., prior to increasine above the 200*F.fass e- -; SURVElttAllCE REOUIREMENTS
- see m \; ! ,
~ '
,zt.17,6. lf ,
b31 8" M " 8tr W 50.54 o) and Appendix J of 10 CFR 50, Option 8, et 5.5.1 exemptions, a(nd in accordance with the guidelines of September, 1995. ( ~ -
*A one-time change is granted to have the containment purge supply and/or M ***'**f exhaust isolation valves for the upper and lower compartment open in Modes -
3 and 4 following the steam generator replacement outage. The cumulative tim
-8*<IT5 3.L,1 days.
for having the valves open in Modes 3 and 4.is limite of those containment purge valves open in Modes 3 and 4. I sealed closed prior to initial entry into Mode 2. Each valve will be i
. l McGUIRE - UNIT 2 3/4 6-2 Amendment No. 156 i
i k b l 1 1
I 5e 8%AT'b
- 5. 5'. 2 CONTAINMENT SYSTEMS
( , l ( SURVE!LLANCE REOUfRENENTS (Continued)) D ~
- a. Deleted
* * " b. Deleted l 4 r rFs 5.L.i -
- c. [
( The accuracy of each Type A test shall be verified by a su test in accordance with Regulatory Guide 1.163, September,pplemental! 1995. hg J l a
@ Oype 8 and C tests shall be conducted, in accordance with 10 CF 1
8 50.54(o) and 10 CFR 50 Appendix J, Optica,4, with gas at P , F . 14.8 psig, at intervals no greater than 24 months except for tests Involving: T Air locks,' '
- 2) '
Dua141ybellowsassembifesoncontainmentpenetrationsbetw the containment building and the annulus, and j 3)
. Purge supply material seals.and exhaust isolation valves with resilient
#"M 4)
G In M.! without draining the g1 col-water mixture from th their diaphragm valves meeting a zero'indicat NF-228A, NF-2338, and MF-234A , if leakage rate errwr) for the diaphrage valves. .These(not including ) i lieu
!!I of tests d ich are otherwise required by Sectiontests may be used i O k .C.2(a) of 10 CFR 50 Appendix J to use air or nitrogen as 1 j
l l l MI - UNIT 2 3/4 6-3 Amendment No.155 O m ae
CONTAINMENT SYSTDts l F. 5, 2-CONTAllW90fT AIR LOCKS . O See nr ty MMM i LINITING CONDITION FOR OPERATION
~
L 3.6.1.3 Each contair.nent air lock shall be OPERABLE with:
- a. Both doors closed except when the air lock is being used for normal i l
transit entry and exits through the containment, then at least one l l air lock door shall he closed. and -- I s .
@ An overall air lock leakage rate of less than 0.05 L, at P,,14.8 psig.
4 [APPLICA8ILITY: MODES 1, 2, 3, ana ,. , ACTION: C
- a. With one containment air lock door inoperable:
- 1. Maintain at least the OPERA 8LE air lock door closed and either j restore the inoperable air lock door to OPERABLE status within
[ 24 hours or lock the OPERABLE air lock door closed, . l 2. Operation may then continue until performance of the next required overall air lock leakage test provided that the l OPERABLE air lock door is verified to be locked closed at least once per 31 days, w1TS 7.(- Z 3. Otherwise, be in at least HOT STAN08Y within the next 6 hours and in COLD SHUTDOWN within the following 30 hours, and
- 4. The provisions of Specification 3.0.4 are not applicable.
- b. With the containment air lock inopecable, except as the result of an inoperable air lock door, maintain at icut. one air lock door l
closed; restore the inoperable ' air lock to OPEiUSLE status within 24 hours or be in at least HOT STAND 8Y within the next 6 hours and'in COLD SHUTDOWN within the following 30 hours. l
]
McGUIRE - UNIT 2 3/4 6-5 Amendment No. 148
l Smw ~~ M ENT SYSTEMS 6. f. L p SURVEllLANCE REQUIREMENTS l 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:
- s. Within 72 hours following each closing, except when the air lock is
' being used for multicle entries, then at least once per 72 hours, by S '
veritying that tnedeal leakage is less than 0.01 tms determined I by precision flow measurements when measured for at'least 30 seconds with the volume between the seals at a constant pressure of 14.8 psi 9 b. By conducting overall air lock leakage tests at not less than P,, 14.8 psig, and verifying the overall air lock leakage rate is within its limit:
- 1) At least once per 6 months, # and
- 2) Prior to establishing CONTA!WENT INTEGRITY when maintenance l has been performed on the air lock that could affect the air !
lock sealing capability.* I
- c. At least once per 6 months by verifying that only one door in each/
air lock can be opened at a time, and
.$ s *waar -
w m 3,g,,2. d. At least once per 6 months by conducting a pressure test to verify door seal integrity, with a measured leak rate of less than 15 standard cubic centimeters per minute. O f I I
#The provisions of Specification 4.0.2 are not applicable.
*This constitutes an exemption to Appendix J of 10 CFR 50.
McGUIRE - UNIT 2 3/4 64 Amendment No. 148 O e~,maa
Discussien of Chang:s Chaptsr 5.0 - Administrativa C:ntrols ADMINISTRATIVE CHANGES 1 A.28 CTS 4.4.5.4.a.8 definition of tube inspection has been revised to clarify that the inspection encompasses the entire tube from entry to exit and is not dependent on where the inspection starts, i.e. it may start on either the hot or cold leg side. This has always been interpreted to allow inspection from either side, however, a literal reading of the CTS could be misinterpreted. This change is incorporated into ITS 5.5.9.4.a.8. A.29 CTS 6.12.1 and 6.12.2 have been revised to change the point of , measurement for the radiation field from 45 cm (18 in.) to 30 cm (12in.). This change is consistent with 10 CFR 20.1601 and is considered administrative. The measurement point only provides a consistent reference to baseline field strength and has no affect on how the plant is operated. A.30 CTS 6.9.2 has been deleted. LC0 actions requiring special reports to be generated have been specifically identified in the Administrative Controls, e.g. PAM report. This change is administrative and consistent with NUREG-1431. A.31 CTS 6.8 has been revised to include the Containment Leakage Rate Testing Program. The ITS 5.5.2 program maintains the acceptance criteria in CTS 3.6.1.2 =d 3.5. M . The addition of the program l is considered administrative in nature since it only moves acceptance criteria from one location to another within the TS. Any changes in technical detail will be discussed in the Description of Changes for Section 3.6. This change is consistent with the program in the NRC model for implementation of option B to 10 CFR 50, Appendix J, enclosed in a letter from C.I. Grimes, NRC, to D.J. Modeen, NEI, dated November 2,1995 for Type A tests. l A.32 The responsibility for maintaining keys for high radiation areas in CTS 6.12.2 has been changed from radiation protection supervision to radiation protection personnel. The CTS could be incorrectly interpreted to imply that responsibility 1:,<;ssigned to a " Supervisor" or manager. Current plant practice does not maintain management personnel within radiation protection on back shifts, however, the keys are under the control of radiation protection personnel on duty. The ITS 5.7.2 provides a clarification only and is considered administrative in nature. McGuire Units 1 and 2 Page A - 78 Supplement 25/20/97l j
INSERT 5 (/ 5.5.2 Containment Leakage Rate Testing Program 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, for Type A testing, as modified by l l 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.
The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 14.8 psig. 1 The maximum allowable containment leakage rate, L., at P., shall be 0.3% of containment air weight per day. Leakage Rate acceptance criteria are:
- a. Containment leakage rate acceptance criterion is s 1.0 L,.
During the first plant startup following testing in accordance with this program, the leakage rate acceptance g criteria are < 0.75 L, for Type A tests. The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. ! I The provisions of SR 3.0.3 are applicable to the Containment . Leakage Rate Testing Program. i l INSERT Page 5.0-8 IO lC l McGuic I '!r i
Justificaticn fer Deviatiens Sactien 5.0 - Administrativo Centrols TECHNICAL SPECIFICATIONS
- 10. Duke Power has elected not to submit a PTLR at this time. The current TS values and limits will remain in the proposed TS. All references to l
a PTLR have been deleted from the proposed TS. 1 1 11. This change reflects the NRC model for implementation of option 8 to 10 l CFR 50, Appendix J, enclosed in a letter from C.I. Grimes, NRC, to D.J. Modeen, NEI, dated November 2,1995 for Type A tests. l
- 12. The change from " greater than or equal to" to " greater than" is j consistent with the referenced Branch Technical Position.
- 13. The current TS for ventilation systems permit continued operation with i an inoperable heater provided a special report is provided to the NRC within 30 days. The proposed report is consistent with the current TS and is provided in a format consistent with similar reports in NUREG-1431.
- 14. The reference in Section 5.6.7 to specific conditions of LC0 3.3.3 is deleted. This format is not necessary to ensure the required report is O generated. References to specific conditions within other specifications has the potential to cause unintentional cross-reference errors in future amendments.
- 15. The 5.5.11 requirements for ventilation filter testing in accordance l with Regulatory Guide 1.52 and ANSI N510 are revised. Exceptions to '
these documents exist in the UFSAR as a part of the approved licensing basis. These exceptions are specifically identified in the UFSAR for each filter unit.
- 16. This change reflects a generic change to NUREG-1431 approved by the NRC as proposed in TSTF-119.
l
- 17. This change reflects a generic change to NUREG-1431 approved by the NRC as proposed in TSTF-118.
- 18. This change reflects a generic change to NUREG-1431 approved by the NRC as proposed in TSTF-152.
McGuire Units 1 and 2 21 Supplement 25/E0/97l
McGuire & Catawba Improved TS Review Coments ITS Section 3.6, Containment Systems 3.6.2-3 DOC L.2 , ITS 3.6.2 Condition A, Required Action Note 2 1
)
i STS 3.6.2 ACTION A. Required Action Note 2 states that entry and exit is permissible for 7 l days under administrative controlif both air locks are inoperable. This Note has been adopted in ITS 3.6.2 ACTION A. The proposed change has been categorized as a Less , Restrictive change. DOC L.2 does not address the proposed change's impact on safety and why the safety impact is acceptable. Comment: Revise the submittal to strengthen the justification for this Less Restrictive change. 1 I DEC Response: i DOC L.2 has been revised to provide additional justification for the proposed allowance. O i mc3_cr_3.6 3.6-6 March 12, 1998 l
I I Discussien of Ch:ngas ! S2cticn 3.6 - Centainment Systems l TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Note 1 is added to the air lock CTS 3.6.1.3 Actions to allow unrestricted access for entry and exit through an inoperable air lock for repairs to air lock components. The Action requfrements to close and lock an air lock door remains applicable, with the exception for brief entry and exit of the air lock to perform necessary repairs. The Note also covers all air lock components, such as the interlock mechanism, that may affect air lock OPERABILITY. The allowance to enter and exit through the air lock door, required closed by the Action, is acceptable based on the low probability of an event occurring that could challenge the containment boundary during the short time the door is open. This change, retained in ITS 3.6.2, is less restrictive and consistent with NUREG-1431. L.2 A note is added to CTS 3.6.1.3 Action a to allow entry and exit into containment via the air locks, if one door in both air locks isaee inoperable and administrative controls are provided to control access. This is acceptablepcmitted for a period of time up to 7 days since each air lock has one operable door and containment operability is maintained. With one door in both air O locks inoperable, containment entry may be required to perform TS Surveillances or Required Actions, or other activities on equipment inside containment. The addition of this Note, retained i in ITS 3.6.2, is less restrictive and consistent with NUREG-1431. I L.3 A Note is added to CTS 3.6.1.3 Action a.2 which modifies the ' requirement to verify an air lock door locked closed every 31 days. The Note allows the verification of locked closed air lock doors, located in a high radiation area, by use of administrative means. This is considered acceptable, since access to these areas is restricted for ALARA reasons. The probability of misalignment of the air lock doors, once they have been initially verified in the. proper position, is small. The addition of this Note, retained in ITS 3.6.2, is less restrictive and consistent with NUREG-1431. L.4 CTS 3.6.1.3. Action a.2 is modified to allow continued operation with one air lock door inoperable. The original requirement limited the condition until the next overall air lock leakage test. This restriction is removed, because the air lock remains capable of performing its safety functions with the remaining OPERABLE door. Therefore, continued operations may proceed McGuire Units 1 and 2 Page L - MO Supplement 25/20/97l
No Significant H zards C:nsid:raticn SIcticn 3.6 - Ccntainment Systems
) LESS RESTRICTIVE CHANGE L.2 (G
The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No l Significant Hazards Consideration for conversion to NUREG-1431. l A note is added to CTS 3.6.1.3 Action a to allow entry and exit into containment via the air locks, if one door in both air locks isam inoperable and administrative controls are provided to control access. This is acceptablepermitted for a period of time up to 7 days since each air lock has one operable door and containment operability is maintained. , With one door in both air locks inoperable, containment entry may be required to perform TS Surveillances or Required Actions, or other activities on equipment inside containment. The addition of this Note, retained in ITS 3.6.2, is less restrictive and consistent with NUREG-1431. , O In accordance with the criteria set forth in 10 CFR 50.92, the McGuire b Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is providea in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposed change does not result in any hardware changes. The containment air locks are not assumed to initiate any analyzed event. The role of the containment air lock is to contain releases from the containment during a design basis accident, and thereby limit the consequences of an accident. The proposed change does not allow continuous operation, such that a single failure could allow a release from containment during a design basis accident. The proposed allowance would limit the time to only 7 days. Additionally, during the period for entry and exit is supervised by personnel and in the event of an accident, the OPERABLE air lock door would be closed quickly, thereby reestablishing the containment boundary. Therefore, this change does not involve a significant increase in the probability or ,e consequences of an accident previously evaluated. ( McGuire Units 1 and 2 Page 7M of 61 R Supplement 25/20/97l
N3 Signific nt HIzards Crnsid:Eraticn S ctien 3.6 - Centainment Systems
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operations. The proposed change allows for continued operation for a period of time up to 7 days when both air locks are inoperable. The proposed change will continue to ensure the containment boundary is capable of being maintained. Thus, this change does not create the possibility of a new or different kind of accident from any accident previous 1y eva1uated.
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not involve a significant reduction in a margin of safety. The allowance to permit entry and exit under administrative controls for a limited time up to 7 days is acceptable based on the smail probabi1ity of an event requiring the Containment air lock to mitigate the consequences of the design basis accidents. The proposed change allows entry into Os containment to perform required surveillance or other required work with one door in both air locks inoperable. The probability l of an event, requiring an OPERABLE air lock door during this time period is sma11. One door remains OPERABLE in each air lock during this time. Therefore, the change does not involve a significant reduction in a margin of safety. O McGuire Units 1 and 2 Page BM of 61M Supplement 25/20/97l
l l McGuire & Catawba Improved TS Review Cossnents ITS Section 3.6, Containment Systems 1 3.6.2-4 DOC L.6 JFD 10 JFD Bases 10 CTS 4.6.1.3.c STS SR 3.6.2.2 ITS SR 3.6.2.2 and Associated Bases CTS 4.6.1.3.c and STS SR 3.6.2.2 require verifying only one door in the air lock will open at a time at 6 month intervals. The interval is modified in the ITS from 6 months to 18 months. The justification (DOC L.6) used states that the 6 month frequency was selected to coincide with the frequency of the overall air lock leakage test, which was specified in 10 CFR 50 Appendix J Option A, as once per 6 months. In justifying the increase from 6 months to 18 months, justification DOC L.6 refers to the allowance to increase the frequency interval given by 10 CFR 50 Appendix J Option B. This portion of the justification is not applicable to McGuire/ Catawba since Appendix J Option B was not approved for airlock leakage testing. (See Comment Numbers 3.6.1-2 and 3.6.2-2). Also, DOC L.6 states that the frequency change to 18 months is consistent with TSTF-17. This is incorrect. TSTF-17 approved a change in frequency for STS SR 3.6.2.2 from 6 months to 24 months. In addition, the modifications made to ITS B3.6.2 Bases SR 3.6.2.2 are not in accordance with TSTF-17. Comment: Licensee to update submittal to be in accordance with TSTF-17 and provide O additional discussions and justifications for the increase in SR frequency as well as the deviations from TSTF-17. DEC Response: Discussion of Change L.6 has been revised to delete the discussion related to 10 CFR 50 Appendix J Option B. The remainder of the justfication provided in L.6 is consistent with the generic change (TSTF-17) Justification and is sufficient to justify the change in frequency. The deleted statement is not the principal justification for this generic change since 10 CFR 50 Appendix J does not specify a frecuency nor require interlock testing. The 24 month frequency allowed by TSTF-17 was not implemented at this time since the current refueling cycle is 18 months. It is clear in the justification for the generic change that the intent is to perform the surveillance in a shutdown condition. A statement is added to DOC L.6 identifying this minor plant specific deviation to a shorter frequency than allowed by the TSTF. The ITS Bases are consistent with the TSTF Bases with the exception of a statement justifying the 24 month frequency. This statement has been added to the ITS Bases with a change to 18 months. The 24 month frequency justification also bounds any frequency less than 24 months. I mc3_cr_3.6 3.6-7 March 12, 1998
Containment Air Locks B 3.6.2 BASES SURVEILLAt:CE SR 3.6: (continued) REQUIREMENTS every 1.8 months. The 18 month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage, ar.d the potential for loss of [TLs timA fWh containment OPERABILITY if the surveillance were performed l
/ .b" N iah'g*g g L with the reactor at power.f The Frequency is based on f engineering judgment and is considered adequate given that J W h % 'O k d *" 5'atn* the interlock is not challenged during the use of the I interlock.
<ft - ha) U /fd id "
- l REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
O l O l F1-~5/20/9T McGuire Unit 1 B 3.6-13 Sp es
Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2 (continued) l REQUIREMENTS every 18 months. The 18 month Frequency is based on the need to perform this surveillence under the conditions that apply during a plant outage, and the potential for loss of h N -4 Frque1 l containment OPERABILITY if the surveillance were performed f , W Q ,j d . [3 with the reactor at oower.f The Frequency is based on JulWAiB k m y,,4 engineering auGgment and is considered adequate given that f ige R the interlock is not challenged during the use of the W # ". j interlock. Q REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
O l 1 O McGuire Unit 2 B 3.6-13 & fpen f d k 5/zu/97
Discussicn of Chingss Secticn 3.6 - Centainment Systems TECHNICAL CHANGES - LESS RESTRICTIVE the interlock function is required. The door interlock mechanism cannot be readily bypassed, linkages must be removed, which are under the control of station processes such as temporary modifications, containment closure procedures, and out of services practices. Failure rate of this physical device is very low based on the design of the interlock. l Histcrically, thi; interlock verification ha; had its frequency chc;cn te coincide ,ith the frequency cf the cycr:ll airlock leakage test. Acccrding t0 10 CFR 50 Appendix J, Optien A, this frequency is ence per 5 month;. Mcwever, Appendix J, Option B, allcw; for an exten;icn Of the Overall air lock leakage tc;t frequency te ; ::ximum cf 30 months. l For the above reasons, it is proposed to change the required frequency for this surveillance to 18 months. In this fashion, the l interlock can be tested in a MODE where the interlock is not required. This change, retained as ITS SR 3.6.2.2, is less restrictive and consistent with Technical Specification Task Force (TSTF)-17 approved change to NUREG-1431, except a shorter 18 month frequency is proposed consistent with the refueling cycle. L.7 CTS 3.6.3 Action c is revised to add an additional method of isolating an affected penetration by allowing the use of a check valve inside containment with flow through the valve secured. This is an acceptable isolation method and does not impact the health and safety of the public. Providing an alternative method of isolating an inoperable containment isolation valve is considered less restrictive. This change, retained in ITS 3.6.3 1 Action A.1, is consistent with NUREG-1431. I l l L.8 CTS 4.6.1.1.a and an associated footnote requires verifying the manual valves and blind flanges inside and outside the containment l are closed. ITS SR 3.6.3.32 and 3.6.3.43 contain a note which l permits valves and blind flanges located in high radiation areas to be verified by administrative means. A similar note is also added to the CTS 3.6.3 and 3.6.1.9 actions to provide the same flexibility for valves required to be verified closed as a result ! of required actions. This is considered acceptable, since access to high radiation areas is restricted for ALARA reasons. The probability of misalignment of these devices, once they have been initially verified in the proper position, is small. The term McGuire Units 1 and 2 Page L - 33 Supplement 26/20/97l
I l i Na Significant H zards C:nsidsraticn S:cticn 3.6 - Centainment Systems , LESS RESTRICTIVE CHANGE L.6 l The McGuire Nuclear Station is converting to the Improved Technical l Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.3.c is revised to extend the testing interval of the air lock door interlocks from 6 months to 18 months. Typically, the interlock is installed after each refueling outage, verified operable with this surveillance and not disturbed until the next refueling outage. If the need for maintenance arises when the interlock is required, the performance of the interlock l surveillance would be required following the maintenance. In l addition, when an air lock is opened during times the interlock is I required, the operator first verifies that one door is completely shut and the door seals pressurized before attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock by testing the interlock on a 18 month interval. O, l Testing of the airlock interlock mechanism is accomplished through having one door not completely engaged in the closed position, while attempting to open the second door. Failure of this surveillance effectively results in a loss of containment i integrity. Procedures and training do not allow this interlock to ' be challenged for ingress and egress. One door is opened, all personnel and equipment as necessary are placed into the airlock and the door is completely closed prior to attempting to open the second door. The current surveillance is contrary to processes and training of conservative operation, in that it requires an operator to challenge an interlock during a mode of operation when the interlock function is required. The door interlock mechanism cannot be readily bypassed, linkages must be removed, which are under the control of station processes such as temporary modifications, containment closure procedures, and out of services practices. Failure rate of this physical device is very low based on the design of the interlock. htcrically, this interlock verification has had its frequency chosen to coincide with the frequency of the overall airlock O 4eakage-test. According tc 10 CFR 50 Appendix J, Option A, this McGuire Units 1 and 2 Page 15M of 61M Supplement 25/20/97l
N3 Significant Hezerds Cinsid:raticn Sectitn 3.6 - Centainment Systems ( frequency i; cnce per 5 month;. McwcVer, ^ppendix J, Optica S, allcw; for an exten;icn of the Overa'l air 1cck leakage test frequency te a maximur cf 30 month;. For the above reasons, it is proposed to change the required frequency for this surveillance to 18 months. In this fashion, the interlock can be tested in a MODE where the interlock is not required. This change, retained as ITS SR 3.6.2.2, is less restrictive and consistent with Technical Specification Task Force (TSiF)-17 approved change to NUREG-1431, except a shorter 18 month frequency is proposed consistent with the refueling cycle. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change arid determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposed change does not result in any hardware changes. The O- containment air lock are not assumed to be an initiator of any analyzed event and are assumed closed in the safety analyses to limit the consequences of an accident. The proposed change decreases the frequency for verifying only one door in the air lock can be opened at a time from 6 months to 18 months. the change insures the air locks are not unnecessarily challenged just for testing since they provide their safety function by staying closed. Additionally, the proposed change does not impose any new safety analyses limits or alter the plant's ability to detect and mitigate events. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated. O McGuire Units 1 and 2 Page 16 M of 61 M Supplement 25/20/97l
( Containment Air Locks Ortenennanc. dubatmosoner,c. ice Conoesrsar anci Iba n B 3.6.2 h BASES (continued) y m , v s . SURVEILLANCE SR 3.6.2.1 {. 8 C- 8 . REQUIREMENTS f Maintaining containmer, air locks OPERABLE requires compliance with the akageratetestrequirementsofA STEy i i n monii,ca ov anoro-rw wl @ W jigigg ny, ,___, w a k,1.L.AHan( This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type 8 leakage tests). The acceptance criteria were established durino initial air lock and containment OPERABILITY testin.g. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall contairunent leakage rate. The Frequency is required by b,
- h Eidix MRey(.11, as allows muuiileaAy approveo exenpy. vm. 3 gp '
qhus. SR J.0 I which Fodauancy extensionsy does nol/ g 0 Q .as % T) The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event g,, A ,5 of a DBA. Note 2 has been added to this SR requiring the M f, g /c f, results SR 3.6.1.1. to beThis evaluated ensures against that air lock theleakage acceptance is proper criteria @ly g accounted for in determining the G E containment leakage 4 l g g * c% ,a r ,e g p _ SR 3.6.2. M h The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment r OPERABILITY. Thus, the door interlock feature s@ ports h containmentOPERABILITYwhiletheairlockisbei%use personnel transit in and out of the containment. testing of this interlock demonstratas that the interlock riodic
/
will function as designed and that simultaneous opening of
%oMd the inner and outer doors will not inadvertently occur. Due to the ourely mechanical nature of this interlock, and given AA Me *A
- tnat the interlock mechanism is egry> challenged when the enntairveent air lock door isMEGD. this test is only re Mpnet W 8'9""
.s4 M M a'.* gired to be pertorneg ggr ex a P d,,e ipe-3 , _ , _ _
_m- r _ (continued) I . . WOG STS Rev 1. 04/07/95
,,,44
%':1% N a % mi G A .
5. br% ) g4 Tht(8,,ALpnp, undt# #t ceduks +L.4 antyh%I L Ins .h a P *j , s,m,lleus * , L g y y 4'.'* s u! W p vry ; A ne t%;% c,6 4 ofeener n a .\ ew.
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t4p p,.r. ~ e ~.n u -
McGuire & Catawba Improved TS Review Comunents ITS Section 3.6, Containment Systems 3.6.2-5 JFD Bases 2 (McGuire only) STS B3.6.2 Bases - ACTIONS ITS B3.6.2 Bases - ACTIONS STS B3.6.2 Bases - ACTIONS first paragraph states the following: "If the outer door is inoperable, then it may be easily accessed for most repairs. It is preferred that the airlock..." ITS B3.6.2 Bases - ACTIONS modifies these sentences as follows: "If the outer door...for most repairs. If the inner door is inoperable it is preferred..." The addition of the words "if the inner door is inoperable" changes the meaning of the sentence. The STS words apply to both the inner and outer doors inoperable while the change would restrict access only if the inner door is inoperable. In addition, this change was not made in the corresponding Catawba ITS, is considered by the staff as generic and is beyond the scope of review for this conversion. Comment: Delete this generic change. DEC Response: The submittalis revised to conform to the STS. O O .<> c ,3.e _ _ s.e.e h.,ch 12. 1eee
Containment Air Locks B 3.6.2 N BASES APPLICABILITY probability and consequences of these events are reduced due (continued) to the pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in l MODE 5 to prevent leakage of radioactive material from ! containment. The requirements for the containment air locks l during MODE 6 are addressed in LCO 3.9.4, " Containment l Penetrations." ( ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perfom repairs on the affected air lock component. If the outer door is inoperable, then it may be easily
- accessed for most repairs. aT the inn e danr v inonerapTeb f l t is preferred that the air lock be accessed from inside
/primarycontainmentbyenteringthroughtheotherOPERABLE j air lock. However, if this is not practicable, or if repairs on either door must be performed from the barrel l side of the door then it is pemissible to enter the air-l lock through the OPERABLE door, which means there is a short l time during which the containment boundary is not intact l (during access through the OPERABLE door). The ability to lf i
open the OPERABLE door, even if it means the containment boundary is temporarily not intact, is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected t( oe open. After each entry and exit, the OPERABLE door aust be immediately closed. If ALARA conditions permit, entry and exit should be via an OPERABLE air lock. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each l- air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock. Complying with the Required 1 Actions may allow for continued operation, and a subsequent l inoperable air lock is governed by subsequent Condition i entry and application of associated Required Actions. l l In the event the air lock leakage results in exceeding the l l overall containment leakage rate, Note 3 directs entry into i the applicable Conditions and Required Actions of LCO 3.6.1, i
" Containment."
\
l A (continued) U McGuire Unit 1 B 3.6-8 l Oppea++'2_,5j;cjg7- ;
Centainment Air Locks B 3.6.2 O BASES APPLICABILITY probability and consequences of these events are reduced due (continued) to the pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the containment air locks during MODE 6 are addressed in LC0 3.9.4, " Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perfonn repairs on the affected air lock component. ) If the outer door is inoperajte,l then it may be easily , a cessed for most repairs. (Tf ~ttis4nner door is inaneraDJD l is preferred that the air lock be accessed frorii inside l primary containment by entering through the other OPERABLE air lock. However, if this is not practicable, or if repairs on either door must be perfonned from the barrel side of the door then it is permissible to enter the air ; lock through the OPERABLE door, which means there is a short ' time during which the containment boundary is not intact (during access through the OPERABLE door). The ability to N open the OPERABLE door, even if it means the containment s boundary is temporarily not intact, is ac.ceptable due to the low probability of ,n event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open. After each entry and exit, the OPERABLE door must be immediately closed. If ALARA conditions pennit, entry and exit should be via an OPERABLE air lock. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock. Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions. In the event the air lock leakage results in exceeding the overall containment leakage rate, Note 3 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1,
" Containment."
(continued) McGuire Unit 2 B 3.6-8 Sv/pi l d 5/20/ F
i s l Containment Air Locks w = =heic. Some wo who L.c Qr.demeriana ma o m. B 3.6.2 Qz. BASES APPLICABILITY probability and consequences of these events are reduced due j (continued) to the pressure and temperature limitations of these KDES. Therefore, the contairnent air locks are not required in K)DE 5 to prevent leakage of radioactive material from contairment. The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9. 'Contairnent Penetrations.' ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock component. / If the outer door is inoperable, then it may be easily / / I accc: sed for most repairs.I s ft is preferred that the air 6e mn r l lock be accessed from inside primary containment by entering ' me ,4 through the other OPERABLE air lock. However, if this is me M g i not practicable, or if repairs on either door must be perforned from the barrel side of the door then it is / permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door). The ability to open the OPERABLE door, O even if it means the containment boundary is tenporarily not intact, is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open. After each entry and exit. the OPERABLE door must be immediately closed. If ALARA conditions be via an OPERABLE air lock. permit, entry and exit should A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensato actions for each inoperable air lock. Complying with the ired Actions may allow for continued operation, and a stesequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions. In the event the air lock leakage results in exceeding the overall containment leakage rate, Note 3 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1,
" Containment.'
l (continued) WOG STS B 3.6-23 Rev 1, 04/07/95 bCha_t l \ i
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.2-6 JFD Bases 2 STS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 ITS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 STS B3.6.2 Bases - RA A.1, A.2, and A.3 states in the description for Note 2 the following:
"This Note is not intended to preclude other activities (i.e., non TS required activities)...to perform an allowed activity listed above." ITS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 modifies this statement to restrict the " allowed activity listed above" to "TS required allowed activities listed above". This change changes the meaning of the discussion and negates the previous Base statements which allows preventive maintenance to TS required ;
equipment and repairs to non TS support equipment would not be allowed as is stated in the l Bases discussion for Note 2. Tne staff also considers this enange to be potentially generic. j Comment: Delete this change. I DEC Response: The submittalis revised to conform to the STS. O l l v mc3_cr_3.6 3.6-9 March 12, 1998
Containment Air Locks B 3.6.2 p ! l BASES l ACTIONS A.1. A.2. and A.3 (continued) entry and exit for 7 days under administrative controls if both air locks have an inoperable door. This 7 day i restriction begins when the second air lock is discovered inoperable. Containment entry may be required on a periodic I basis to perform Technical Specifications (TS) Surveillances and Required Actions, as well as other activities on l equipment inside containment that are required by TS or i activities on equipment that support TS-required equipment. 1 This Note is not intended to preclude performing other ' activities (i.e., non-TS-required activities) if the containment is entered, using the inoperable air lock, to perform an alloweddS-penuwee activity listed above. This ; allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open. l B.I. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated l r\ Completion Times are consistent with tho.se specified in Cond.ition A. l The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated l Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and i exit from containment under the control of a dedicated I individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock). l Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. p (continued) McGuire Unit 1 B 3.6-10 GyW-L 5/ZO/F
I ! 1 l Centainment Air Locks B 3.6.2 BASES l 1 ACTIONS A.1. A.2. and A.3 (continued) entry and exit for 7 days under administrative controls if both air locks have an inoperable door. This 7 day restriction begins when the second air lock is discovered inoperable. Containment entry may be required on a periodic basis to perform Technical Specifications (TS) Surve111ances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e., non-TS-required activities) if the containment is entered, using the inoperable air lock, to perfonn an allowed damuuwee activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open. l B.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated N Completion Times are consistent with those specified in Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the control of a dedicated individual stationed at the air lock tu ensure that only one door is opened at a time (i.e., the individual perfonns the function of the interlock). Required Action 8.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows i these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access l to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been ; verified to be in the proper position, is small. l (continued) , Oi l McGuire Unit 2 B 3.6-10 EPfkW 5#0/97--
Containment Air Locks (Atmospheryc wr--nene. Ice Londeuser. and tgD 2 B 3.o.2 BASES ACTION! A.1. A.2. and A.3 (continued) entry and exit for 7 days under adninistrative controls if both air locks have an inoperable door. This 7 day restriction begins when the second air lock is discovered inoperable. Containment entry may be required on a periodic basis to perform Technical ifications (TS) Surveillances and Required Actions, as wel as other activities on equipment inside containment that are required by TS or activities on equipment that s p ort TS-required equipment. This Note is not intended to preclude performing other activities (i.e.. non-TS-required activities) if the
' ' containment is entered, usin the inoperable air lock, to oerform an allowed 1 activity isted above. This allowance is I "T/-dw[.-Vf acceptable due to the low probability of an event that could
)
, , , - pressurire the containment during the short time that the OPERABLE door is expected to be open.
B.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or O more air locks, the Required Actions and associated Completion Times are consistent with those specified in Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the control of a dedicated individual stationed at the e4r lock to ensure that only one door is opened at a time (i.e., the individual performs the ftriction of the interlock). Required Action B.3 is modified by a Note that applies to air lock doors located in hi radiation areas and allows these doors to be verified 1 ed closed by use of administrative means. Allowing verification by adeinistrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position. is small. (continued) WOG STS B 3.6-25 Rev 1. 04/07/95 (_ VIC & YE r
l McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.3 Containment isolation Valves 3.6.3-1 DOC A.5 (ITS 1.0) CTS 1.7 See Comment 3.6.1-3. Comment: Revise the CTS markup of ITS 3.6.3 to include a markup of CTS 1.7. Provide additional discussions and justifications for the Administrative changes. DEC Response: See response to comment 3.6.1-3. 1 O l i t i O
I McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems t 3.6.3-2 DOC A.1 JFD 1 JFD Bases 1 CTS 4.6.1.2.e (Catawba) CTS 4.6.1.2.f (McGuire) ITS SR 3.6.3.7 and Associated Bases ITS B3.6.3 Bases SR 3.6.3.5 CTS 4.6.1.2.f specifies that the combined bypass leakage rate shall be determined "during each Type A test". This material has not been retained in ITS SR 3.6.3.7. The proposed change has been categorized as a reformatting, renurnbering, or rewording type change. As a result of the discussion in Comment Number 3.6.1-2, this phrase cannot be deleted, but must be included in some form in the frequency for ITS SR 3.6.3.7. In addition, the Bases for ITS SR 3.6.3.5 and SR 3.6.3.7 need to be modified in accordance with Comment Number 3.6.1-2. Comment: See Comment Number 3.6.1-2. DEC Response: The phrase in question or:ly applies to penetrations which are not individually testable. In these cases, the CTS allows these penetrations to be tested with soap bubbles during Type A testing while the containment is pressurized. The Type A tests are performed by 10 CFR 50 O 1 Appendix J, Option B. Therefore, the frequency of the Type A tests will not be the same as for Types B and C testing which is performed for the other penetrations. The frequency has been modified to require penetrations not individually testable to be tested during Type A testing consistent with the CTS requirements. l
. k .
l _
Containment Isolation Valves l 3.6.3 1 . SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY
' SR 3.6.3.h Verify the isolation time of automatic In accordance l power operated containment isolation valve with the l is within limits. Inservice !
Testing Program l SR 3.6.3. h Perform, leakage rate testing for 184 days } l containment purge lower and upper ' compartment and Instrument room valves with MQ resilient seals. within 92 days after opening the valve j SR 3.6.3. M Verify each automatic containment isolation 18 months ! valve that is not locked, sealed or , s otherwise secured in position, actuates to l the isolation position on an actual or , simulated actuation signal. l SR3.6.3.M ------------------NOTE------------------- ------NOTE----- l Penetrations not individually testable SR 3.0.2 is not shall be determined to have no visible applicable. leakage when tested with soap bubbles. ---------------
----------------------------------------- In accordance with 10 CFR 50, Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P ,14.8 approved psig. m exemptions, b
'g ** j 4c kte Tw@4%4 et.
AuD Dudaj 3R 3.4.I I Tyn. A hsh b PWbb "4 ikdevka hs R. McGuire Unit 1 3.6-13 Svpph+Q - 5/20/97-- l
Containment Isolation Valves 3.6.3 O SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.6.3.f(D Verify the isolation time of automatic In accordance power operated containment isolation valve with the is within limits. Inservice Testing Program l SR 3.6.3.h Perfonn leakage rate testing for 184 days l j ! containment purge lower and upper I compartment and Instrument room valves with MQ l resilient seals. within 92 days after opening the valve SR 3.6.3.h Verify each automatic containment isolation 18 months k valve that is not locked, sealed or
- s. otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.
SR 3.6.3. 4 ------------------NOTE------------------- ------NOTE----- Penetrations not individually testable SR 3.0.2 is not shall be detennined to have no visible applicable. leakage when tested with soap bubbles. --------------- In accordance with 10 CFR 50 Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P ,14.8 approved psig. exemptionsjf.e Bad Tyty ksM k (wc W$.~ Ed 0*L asa 3 t.t.t Tyg A wsh L
% % nd m a % t3 g, a McGuire Unit 2 3.6-13 Jurfbt L 5/20/97--
l l
Containment Isolation Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3. 6. 3.N REQUIREMENTS l (continued) Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.6.3.d l. This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J maximum pathway leakage limits are to be quantified in accordance withAppendixJ). Penetrations which are not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurize ' The Frequency is required by 10 CFR 50, 1
, Appendix J, as modified by approved exemptions (and bi $ b 9(* **
- p y ,'
Su kii M Lnus k {<.M L (continued) McGuire Unit 1 B 3.6-27 SuppbML-6/20/97 -
1 l Centainment Isolation Valves ' B 3.6.3 BASES SURVEILLANCE SR 3.6.3 (continued) REQUIREMENTS l therefore, the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J. Type C test. This SR simply imposes additional acceptance criteria. i Bypass leakage is considered part of L . 6v REFERENCES 1. UFSAR Section 15.
- 2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 3. UFSAR, Section 6.2.
- 4. Generic Issue B-24.
- 5. Standard Review Plan 6.2.4.
i i O , McGuire Unit 1 B 3.6-28 S u@+W4jggjg7
Centainment Isolation Valvas B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3.1I b REQUIREMENTS (continued) Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perfonn this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were perfonned with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be. acceptable from a reliability standpoint. SR 3.6.3.M This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by : use of one closed and de-activated automatic valve, closed ! manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J maximum pathway leakage limits are to be quantified in accordance with Appendix J). Penetrations which are not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurized The Frequencffis required by 10 CFR 50, ' AppendixJ,[,asmodifiedby(approvedexemptions(and hurin3 Sn %.\.\ b m.J;aAha
~Ty A bb..3 J J t (continued)
McGuire Unit 2 8 3.6-27 gg W r_.5/20/07
i Containment Isolation Valves
,~ - B 3.6.3 l ,
BASES i SURVEILLANCE SR 3.6.3.p(continued) l REQUIREMENTS therefore, the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J. Type test. This SR simply imposes additional acceptance criteria. B .- Bypass leakage is considered part of L,. l l REFERENCES 1. UFSAR, Section 15.
- 2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 3. UFSAR, Section 6.2.
- 4. Generic Issue B-24.
- 5. Standard Review Plan 6.2.4. ;
l O V McGuire Unit 2 B 3.6-28 0"f/ O 5/?0/97
Q Cth atk h. 8 6 3
. i CONTAINMENT SYSTDtS_
SURVEILLANCE REOUTREMENTS (Continued)
. ~
f 85 ###k the test medium. _g,,- l15 5.fra/ interval are not changed by this exception.The above require e. Purge supply and exhaust isolation valves with resilient material seals shall be tested and demonstrated OPERABLE by the nquim f taar4 f temthn a_E.1.e_1 er a E.1.9.a _ at maaliemh1=* #
!4 3. /,3,% (ppH)f. C The combi fewer la*/tmf Bypnss /%e MND e e.07 am -- rete '- m == m rie ~~iess * ==
j3, ( F. itcasse Typys amp c tgsi.s avaeast ==- per ze . g,gg / f angp penetrations not individually testable sha11 be deter 'yp jogoavc/gmeensk Leo detectable leakage h _to hav tested with sean W ie i e ",he con-tainment is pressurtzed to P.,14.8 psig s. - s-s (g. WrerS;Es- l
/ 8 g i Specification 4.6.1.3; Air locks shall be tested and demonstrate
. $TET "tytAgd*5 h. pgp,qq The space between each dual-ply bellows assembly on containmen I
gge penetrations be vented to thebetween the containment Type A tests. building and the annules sha N of each Type A test annulus during M IN'0 assembly shall be su,bjected to a low igpressure to 4 te verify no detectable leakage or the dual-ply bellows assa y shall be subjected to a leak test with the pressure on the contalement side of the dual-ply bellows assembly at P 1eakage to be within the limits of Specifi.,14.8 psig to verify the l cation 4.6.1.2f.; i I O 1. All test leakage rates stia11 be calculated using observed data
. converted to absolute values.
lect a balanced Integrated Leakage Measurement $ystem gec 5f h @povisigof Sepc1ftsation 0.2gnotapplicable. fregueom Q) NDtt, Un 4 McGUIRE - UNIT 1 3/4 6-4 Amendment No.173 gt /hab & O
quc436'n. s.s 5 CbNTAff#f0fT SYSTEMS . SURVEILUWICE REQUIRENDITS (Continued 1~ l i fed Nat'4 the test medium. o f 175 3. 4o interval are not changed by this exception.The above require e. i purge supply and exhaust isolation valves with resilient material seals shall be tested and demonstrated OPERABLE by the requ of specificattaa a s 1 o t a A 8.1.g a; == =aalicable-J 54 e.r,.3. krit k4 rot 3# 8 ou6ined F ues "== M - BarVaa, W m kose]
* - rate saan no-ne ;mst p l -
N * " ' M C**"" " **'*meer t4.ess
*" than I
ffo eter/entewiM gen,jff,,,/,r.7l/s'h acept for penetrations which are.not individually testable; WD O
~~ ~2 netrations not individually testable shall be detem'ned to ha /A38 g jpf g 7,.jpe/ detectable 1== h r: se== tested with saan _"les/wh Te~sne W i tainment is pressurized to P ,14.8 psig gf 7y ,m irIMrA tes i
7 6n {g. j Air locks shall 5pecification be tested and demonstrated 4.6.1.3; LE O perMP '. T'
- h. SR Fretv'Q- !
The space between ead dual-ply bellows assembly on containmen be vented to the annulus during Type A tests. penetration of each Type A test
/fedAfdf/( the space between each dual-ply bellowsFollowing c
, sf /T5 3 4,/
assembly shall be su,bjected to a low pressure test at 3-5 esi
- verify no detectable leakage or the dual-ply bellows assembly shall
( be subjected to a leak test with the pressure on the containment side of the dual-ply bellows assembly at P 1eakage to be within the 11sdts of specifi.,14.8 psig to verify the cation 4.6.1.2f.; - l i L 1. All test leakage rates shall be calculated using observed data converted to absolute values. A'I t select a balanced Integrated Leakage Measurement System [ (heMvisigof 5fdeifi Sati 0.2 4 9 not applicable. i McGUIRE - (MIT 2 3/4 6-4 Amer.dment No.155 l 'O g ao
~
7 Containment g r =. . . . : _ , vIsolation
, ,_ ~ - - ._ valves
. == .. pf=-:+Yn,acb m Q 3.6.3 7
SURVEILLANCE REQUIRBIGNTS (continued) SURVEILLANCE FREQUENCY I egvVeri SR 3.6.3. the combined leakage rate for all -----NOTE cac building bypass leakage paths is* SR 3.0.2 5 4 LAwhen pressurized to (2 I Aiol. ' is not applicable 4,N I d.$ . h s W In with a ,
/\
10 CFR 50, Appendix J, as modified by approved exemptions y f-
,;bTve.SeJ C ;
.- ksJ.A.5thba. 4
^
NOTE - - - - n"P sn.s.u.t
?enen r1+io g not ehds0iduall9 4<iln Ne- \ hkgf^',). '~b:O An c e se<< An ed -to hm no ,
' k' WI'b vlia ble lea k'a y. Whe.6 t erit <J/ wif.h '
q . se a.p _ b ub b l'es . . em , , _ __ _ -g e
- Y e
4 I l nr
5 , Containment Isolation Valvesj Atmosphe c
,_ re , m <- = - - # h B 3.6.3 BASES d l SURVEILLANCE SR 3.6.3. d (continued) -
REQUIREMENTS maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If r both isolation valves in the penetration are closed, the h actual leakage rate is the lesser leakage rate of the two valves. is only to beThis method used for of quantifying this SR (i.e., maximum pathway Appendix J maximum pathway leakage limits are to be quantified in accordance - h Q ,n J..A 3" " with Appendix J).3The Frequencyyis reouired bv 10 CFR 50, ja,Jaj$LM) 5b"\t penoix d, as modified by approved exenptions ( ( Ng.** g , ,u t h t ..t . t erefore, the Frequency extensions of SR 3.0.2 may not be !.k^^ dew 1 les.n ) applied), since the testing is an Appendix J. Type test. JA Uj y,) ) t L . .,h,,4 A l This SR simply imposes additional acceptance criteria. /okh
"'{"
yk. M .] IRevjeWEr3 * % l
%fBv nass leakaae is considered nart of L,.
[**f""'" Glote:Enless specifistrTlf exempted).7) {\ . 5g.3.L.0 - - S
,1. @ SAR, Section'f.151 7
{ . @SAR, Section 16.2&. 1
. ric Issue B-20, 'Corgainment Leakage Due/t o Seay erioration." e g 4. Generic Issue B-24.
f GS. $tanderd Tevseul Fla n 4,S. b M hp,Q 60.3% fitJurseuf Speu$ca.bSS, W N 9
= STS- B 3.6-44 Rev 1, 04/07/95 O mes 1
l
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems k/ 3.6.3-3 DOC A.10 JFD 2 CTS 3.6.3 Insert 6 STS 3.6.3 ACTIONS Note 4 ITS 3.6.3 ACTIONS Note 4 ) STS 3.6.3 ACTIONS Note 4 requires entry into " Applicable Conditions and Required Actions of LCO 3.6.1 " Containment", when isolation valve le.tkage results in exceeding the overall containment leakage rate acceptance criteria." ITS 3.6.3 ACTIONS Note 4 deletes the STS words " acceptance criteria," based on editorial change for clarity. The staff finds the change is not an editorial change and considers the change to be generic which is beyond tha scope , of review for this conversion. Comment: Delete this generic change. ) DEC Response: The submittal has been revised to conform to the STS. l a 4 . $
Centainment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS __-_---_-_-------------------------NOTES------------------------------------ I. Penetration flow path (s) except for containment purge supply and/or exhaust isolation valves for the lower compartment and instrument room may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the O overall containment leakage rat . --.____-_--__-__________-_--_------ N D b9& Nib -----_.-------._ _-
CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Isolate the affected 4 hours Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves. de-activated automatic valve, closed manual valve, One or more blind flange, or penetration flow paths check valve inside with one containment containment with flow isolation valve through the valve inoperable except for secured. ; purge valve or reactor l building bypass A!El , , leakage not within ' l limi t. (continued) O McGuire Unit 1 3.6-8 EvfPkd' W i
I Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LC0 3.6.3 Each containment isolation valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. l ACTIONS
-------------------------------------NOTES------------------------------------
i 1. Penetration flow path (s) except for containment purge supply and/or i exhaust isolation valves for the lower compartment and instrument room may j be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
l
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LCO 3.6.1,
" Containment," when isolation va ve leakage results in exceeding the O overall containment leakage rate ...__.._______..........__....___.....m_-..gg y -
CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Isolate the affected 4 hours Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves. de-activated
---------------------- automatic valve, closed manual valve, One or more blind flange, or penetration flow paths check valve inside with one containment containment with flow isolation valve through the valve inoperable except for secured.
purge valve or reactor - building bypass M leakage not within limit. (continued) O McGuire Unit 2 3.6-8 Fvr[ d % /20/ W i
Specification 3.6.3 Insert 6
--------_---------------------------NOTES----------------------------- ------
- 1. Penetration flow path (s), except for containment purge supply and/or L3 exhaust isolation valves for the lower compartment and instrument room, ,
may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria. l O Insert 7 A.0
-----_--------------_----------------NOTE------------------------------------- ,
Only applicable to penetration flow paths with two containment isolation valves. l McGuire U2Y I Page 2-. of l 7,,.
L Specification 3.6.3 Insert 6 ! .-_-------------------.-------------NOTES-------------------------------__--- 1 AA 1. Penetration flow path (s), except for containment purge supply and/or g exhaust isolation valves for the lower compartment and instrument room, I may be unisolated intermittently under administrative controls. A.It 2. Separate Condition entry is allowed for each penetration flow path. ] l 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria. l
\ l l
\ Insert 7
.T i
-------------------------------------NOTE-------------------------------------
Only applicable to penetration flow paths with two containment isolation valves. i l McGuire U/,-f L Page 7--of l7 - (
i i o containment m ygyx Isolation Valves At s "- % u._--- g , m=-- -- nnm11) 3.6.3 b l 3.6 CONTAIISEENY SYSTetS T
- l l 3.6.3 containment Isolation valvesJ ktanopheriWi Subdmaaphorig; I Gondenser, And Dual), ' '
Lco 3.6.3 Each containment isolation valve shall be OPEIUWLE. l APPLICABILITY: NODES 1, 2, 3, and 4. 6% ppb s g/or erkaush Lisolodme r-bire / outer"confNW ncrIcagg Goalummh ,,,w ont vsom . e @ 1 Penetration flow path (s) Remospt enTTR9t purgelvaldimE7jGTErt may l be unisolated intermittently under administrative controls.
- 2. separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems sede inoperable by containment isolation valves. '
- 4. Inter applicable Conditions and Required Acticr.s of M30 3.6.1,
" Containment," when isolation valve leakage results in ==a== ding the overall contain==nt leakage rate h g 7 CONDITION REQUIRED ACTION CDuPLETION TIME A. 2 A.1 Isolate the affacted 4 hours only applicable to penetration flow path penetration flow paths by use or at least with two containment one closed and /6 isolation valves. de-activated .
automatic valve,
- i closed manual valve, QeR One or more blind flange c U6-y l penetration flow paths check valvefwith flow with one containment through the valve l isolation valve secured.
s inoperable leecept for . purge valve or 451 i building bypass f leakage not within 't" limitA. (contirn d ) mes-ass- 3.6-8 Rev 1, 04/07/95 Aku r< a
McGuire & Catawba Improved TS Review Conuments ITS Section 3.6, Containment Systems 3.6.3 4 DOC A.10 (McGuire Only) DOC L.8 CTS 4.6.1.1.a, " Footnote l ITS 3.6.3 ACTION Note 1 CTS 4.6.1.1.a, seems to limit the containment isolation valves allowed to be opened under administrative control to those listed in the " footnote. This footnote has not berr,1 retained in ITS 3.6.3 and its deletion is justified by DOC L.8. ITS 3.6.3 ACTION Note 1 added by DOC. , 1 A.10 allows all conta!nment isolation valves except the purge valves to be opened I intermittently under administrative control. Because of the " footnote to CTS 4.6.1.1.a the ! addition of ITS 3.6.3 ACT!ON Note 1 is a Less Restrictive change, not an Administrative change. In addition, DOC L 8 does not discuss the deletion of the " footriote, nor why this deletion is a Less Restrictive change. Comment: Revise the submittal to classify the addition
- of ITS 3.6.3 ACTION Note 1 as a Less Restrictive change and provide additional discussion l and justification for the Less Restrictive changes of the addition of ITS 3.6.3 ACTION Note 1 l l
and the deletion of CTS 4.6.1.1.a. " footnote. DEC Response: 3, l DOC L.8 is not related to this change and is removed from the McGuire footnote. New DOC l( lg L.31 has been added to both Catawba and McGuire to justify this less restrictive change. DOC A.10 is still applicable for the existing allowances, but is revised to reference DOC L.31. l l t mc3_cr_3.6 3.6-13 March 12, 1998
Spec.skrabor1 3.(* 3 l CONTAltf1ENT. SYSTDtS 30 3 d7FPb CONTAlfelENT IS0ULTION VALVES ONtTwenanIrsom rosvnpreATIfb QhA Fo '?' *FS"""' 'a"" :'h* ***"? '"E-- ~" a "-"Mb I SPPLICA8ILITY: MODES 1, 2, 3, and 4. '"/ D b 4,85 'I MN : i n d wos A na p # co w dh on h <Ange. W E.atherQ byft% hithoneormore a 4 .f u.,. _ a.,;.a.. i antainment m,m_, i n e.m.r isolation rm _.m . . valve u,. @ inoperableh. n- - ntain a re the inoperable /alve(s) to OPERABLE stat #t within 4 hours 6 Isolate ected penetration within 4 hours b use of at least Q one deactivated automatic valve secured in the iso ation posith Acried 4.1 or (cde<>: eez/etsmadeapshayam7 IJMi Noe d , rected penetration within 4 hours by use of at least #p.g, ,. fee, wi l Isolate --
.g AT'#N d'2- one closed manual valve or blind flange, or r ,.
1 hMU d9 Se in at least NOT STANDBY within the next 6 hours and in COLD SHUT 00WN within the following 30 hours. g;,,g g
- e. The prov tons of Specification 3.0.4 a not applicable provided
#U'#^# 0 l4 $
that t affected penetration is isol ed in accordance with ACT
- b. or . above. and provided that th associated system. If app -
h cab , is declared inoperable and appropriate ACTICII stat ets;
/svytAr to fo that system are perfossed. f
'*N SURVEILLANCE RE0llfilDIENTS
( (C4.3.1 Eas ^the wasainment isolation valve valve to service after ll oe oemonstrates w., at p or'
, to returnt ntenance, repair or replacemen wort is = ormed on the valve or its a lated actuator, control or r kircuit performance of a cycline tes and verification of isolation iae.
.s 4, A c. u,wa me.O 54 3. G. 4. ... a solation valwea s hall l&strated OPERABLE difiNiio""Ee"2NllM/5 dX :
/ech/, *'* E! ce j
r=- ar wrmi = ===iat Feast pace per 18 noeths by 58. {g ,,,#;fgg. vertrytel At on a Phase A Contai. ... nosauen test signes weda/A*N'd'M _ Phase A dolation valve actuates t its isolation position, . {fu'rf8'5 d'* M s b. Verify
,,a 8 that on a Phase s...e .n val.e B .Con
,es,,, n, t,at o, a, .
imment Isolation test st s to its isoi.e o.
. .. -~ ...-
- le . -
s,,a, 1, e gNga.,,y,_
.aa.J 4, g psfry and exhaust valve agthates to its isolation itlan_ Sfm 14 /,d i 54 4.4. The isolation time of eachCoower aa.ra..ma automatilvalve t-- - --
-. ------m W l
&enestina to ne@ within e-w wu.i a u.e.
,e e u n ,
s i. , - McGUIRE - UNIT 1 3/4 6-16 Am mlaent No. 166 e O 1 Pge /cf /2.
Specification 3.6.3 O Insert 6
--------_-__------_-----------------NOTES------------------------------------
- 1. Penetration flow path (s), except for containment purge supply and/or LL3 exhaust isolation valves for the lower compartment and instrument room, ,
may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance crfterfa. l O Insert 7 A.0
-------------------------------------NOTE-------------------------------------
Only applicable to penetration flow paths with two containment isolation valves. McGuire U2Y I Page L of 12 -
S,otC$16th ?t 2. (p.3
~ .
h4.6 CONTAINMENT SYSTEMS .. ,, , 3/4.6.1 PRIMARY CONTAINNENT
. , CONTAIMENT INTEGRITY LINITING CO WITION FOR OPERATION Set AldrNy 1
& /T5 3.4./ 3.6.1.1 primary CONTAlfftENT INTEGRITY shall be metatafaed.
APPLICASILITY, MODES 1, 2, 3, and 4.
- l sum, -
lifthout primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within I hear er be SWTDOW la the withis at least followfNOT ag 30 STAW8Y hours. withis the next 6 hours and in COLD g,g SURVEILLANCE REOUTROfENTS fyse(f // .6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstratede J
.st! ,.6 3, @_ At least once per 31 days by verifyfag that all . penetrations
- act */
Se S. 68. capable of being closed by OPERABLE contatament automatic (solation l valves or operator action during periods whenlentainment isolation valves art open under adelaistrative control (6aCnquired to i.losed dorlog accident condittens are closed by valves, blind ll flanges, or deactivated automatic valves secured la their positions: T By verifyfog that each contalament air lect is la compitance with Specification 3.6.1.33 and c. SCC Mk jd After each clostag of each penetration subject to Type 8 testing, O g j g 0'j except the contalement air locks, if opened followf ag a Type A er 8 test, by leak rate testtag the seal with gas at P verifylag that Men the measured leakage rate for. 14.8 psig, and these seals is added to the leakage rates deternised pursuant to Specification 4.6.1.2d. for all other Type 8 and C penetrations, the codined leakage rate is less than 0.60 t . -- hh - 54 F.6 3. *Except valves, blind flanges, and deactivated automatic b a 1 5#E64 located teside the costalement and the aansles andliiT1ecked, ' valves othetvise secured in the closefposities. These penetratieasyshall which sealed or are *"N"$' be J . verified closed during each COLD SWTDOW except that such verification need met be performed mort eften than once per 92 days.
**The fell valves may t
.') 4 tra i ew): NC-14 en as laiduittent hast[under adst
-142, llE-13.)(-23. VX-34. K-40 FW-11 -13 i
ene-time change is granted to have the costalement purge supply and/or exhaust isolation valves for the apper and lower compartment spea la Modes U6 3 and 4 fellewlag the steam generator replacement estage. The cumulative g fg 3 ,f time for havias the valves spea la Modes 3 and 4 is limited to fevrteen (14) days. All other provisions of this specificattee apply with the exception of those contalement perye valves open la Modes 3 and 4. Each we will be sealed closed prior to initial entry into Mode 2. McGUIRE - tal!T 1 3/4 6-1 Amendment No.174
,0.tf< & ob G O
fpccstecaktoV1 l 540 CONTAI19 EIT SYSTEMS J.4 5 (TK~UI) tmTAIISIENT 1581 ATION VALVES (DNI21E P""*ITIdd FOR C?C:t.TISD b
/co 3.6.3 @tainment isolaties valves shall be OPERA 8LE Arith isolattosytimes) u- u - i - - irwe uvie u ww u sses .i -
,1 APPLICABILITY: N00E5 1, 2, 3, and 4.
carmt Wrayt mfWC
/g ,,. pa, r.
(INStB.f4f fjarsee6*n.6en hso JedMA '"'% 0'b' / 4 %f* *G5 ith one or more tainment isolation valve @ inoperable, JaintaTn at #'"" age isolatiom vsITy wu wind IR Wagn sTTWCIEE -- iraLTom that i5 - feast) % 4.ff (a. tore the inoperable v4Tve(s) to uruuwu sNases within 4 f@ Isolate affected penetration within 4 hours by use of at least AcnaN A.i t one deactivated automatic valve secured in the isolation sositian _ _ e,f or M o de. ,,A //, , k Isolate ffected penetration within 4 hours by use of at least one closed saneal valve or blind flange, erf ' Aadod d. Se in at least HDT STAND 8Y within the next 6 hours and in COLD E3 Acused A.2. . F SWTD0lAl within the following 30 hours. 8 # d"# . The p isions of Specifica en 3.0.4 are not app cable providee g,,,y , that affected penetra on is isolated in acc with ACT!
- b. o c. above, and prov that the associa g
/Nmr f system, if app - i Acab , is declared i le and the aserne te ACTION stat ' ts) g7,,u g \fo that system are ormed. f NW #8/ summituNer REnufaENENTS 9.6.3.1 - containment isolation valve 11 be desenstrated OPERASLE o to returni valve to service after se , repair or replac 44.5 wort is ormed on the valve or its as lated actuator, control or r .sf (circuit serformance af a cycling test vertfientian of isolatio ice 5at s.m MA / I wh1 btrated OPEF'ABLE diiR$21ie~1RB /
----- or m
,f" l
-- at least once per 18 anoths 1( "
[ A. Vehfying on a Phase A Contal savisuun test signas, ca I Phase A, iso ation valve actuates to isolation position.
- b. Verifyi t on a Phase B Cental Isolation test signa each I ba.h*^
gg ,,g Phase 8 lation valve actuates its isolation position, ad
'c. Verifyld.that onb*=t===t ehdioact< vity-nialb test si 1, eac ' p sit:4n en N w And =~t valve actuate ( to - ts < so' ation sositt 4.nedvd
#4 5.6.5.O c I33 The
- i, solation.t.ime to e .ith iisi.m__.of.each m .. 7 sover ... ,.omeratasa_p
- b[
%automa d b g w-yce aQ --
L.29 se .c. nan rd 9 % s.1 McGUIRE - istIT 2 3/4 6-16 . Amendment No. 148 O p+ Ida-
Specification 3.6. *3 I Insert 6 l ------------------------------------NOTES------------------------------------
- 1. Penetration flow path (s), except for containment purge supply and/or exhaust isolation valves for the lower compartment and instrument room, L3 may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path, i
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
4.1
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance crf teria. l 1 f~
\ Insert 7 l 4.0 l
-------------------------------------NOTE------------------------------------- l Only applicable to penetration flow paths with two containment isolation l valves.
1 l r McGuire U a Y 1 Page2 _- of l p L. _ __ _ _ _ _ _ _ _ _ _ _ _ _
SeCAt?Ab$n j 9,5 3/4.6 CONTAINMMT SY$ims .
, 3/4.6.1 PRIMARY CONTAfgggI GENTAllseff INTEGRffY See 49typ trNrTING CaorTIm m OPERATION N
- 4 / T5 3.f,/ 3.6.1.1 primary CONTA1100ENT INTEGRITT shall be maintained.
APPLICA8fLITY: M00E3 1, 2, 3, and 4. *** EIlg: Without primary CONTAllplENT 111TERRITY, restore CONTAllelENT INTE I bour orwithis SIEIT90let he the la following at least30IIOT hours. STAlWST
~
withis the next 6 hours an SURYEILLAllCE REOUIREMENTS
/,7 I4.6.1.1 c primary CONTAtletENT IllTEGRITY shall be demonstrated: [
f g // h '@ At least once per 31 days
/ verifying that all penetrations
- act :
# Mgk3 capable of betag closed valves or operator actf alABLE contalament automatic isolation, g gg,g valves are open under adofaistrative controlgand required to be closed during accident conditions are closed by vaim, ^ ii.i
- i flanges, or deactivated automatic valves secured ia their posttior.
[b'. 1 Specificatica 3.6.1.3; andBy verifytag that each containment air lo c. g Afg*/* \N After each clostag of each penetratfe'* a subject to Type 8 testing,
" except the contatament air locks, if opened followlee a Type A or 8 test, by test rate testing the seat with gas at p ,14.8 psig, and O
g jp; y'4* / vertfying that when the measured leakage rate for*these seals is added to the leakage rates determined pursuant to s l 4 j k.6.1.2d. for all other Type akage rate is less than 0.60 L,. 8 and C penetrations, pecifica Y O* 0'3'N *Except valves, blind flanges, and deactiva h>Mt. hehE'A i located faside the contataneet and the annales o. *Redoc 2343,[ etherwise securvd la the el arestomatic valves locked, sealed orlwhich stemne, are , l verified closed during each position.* These penetrationseshall be ' need not he perfoewed more often than once per 32 days.Sin l
.T **The trative following control:valves any se openes on as latermitteet basis moder adminis f
FW-4. 110-141, 81C-142, llE-13, ifE-23, VX-34. VK-40, FW-11, FW-13 I
;,ec gu *"A one-time chmage is granted te have the contalaneet 3 and 4 following the steam generator replacenest outage.
7 b j 15 S.O time for having the valves open in Modes 3 and 4 is limited to fourteenThe cumulat (18) 8875. All other provisions of this specification apply wtth the exception of those containment purge valves opea la Modes 3 and 4. valve will be sealed closed prior to initial entry (ato Mode 2. Each )
/
McGilIRE - Ull!T 2 3/4 6-1 Amendment No.156 fdM b*N
i l Discussicn of Ch:ng:s Secticn 3.6 - Containment Systems ADMINISTRATIVE CHANGES i A.8 CTS 3.6.1.3 Action a.4, providing an exception to CTS l Specification 3.0.4 is deleted. This exception is no longer required because the Actions retained in ITS 3.6.2 allow continued operation for an unlimited period of time. LC0 3.0.4 does not allow MODE changes when the LC0 is not met, unless an exception to LCO 3.0.4 is specified or if the actions to be entered allow continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This change is administrative because no technical requirements have been l changed. This change is consistent with NUREG-1431. A.9 The specific details of CTS Surveillance 4.6.1.3.a and b are replaced by a more general requirement to perform airlock leak rate testing as required by 10 CFR 50 Appendix J, Option A,4e Containment !cakage Rate Tc;t Program and two Notes. The Notes are added to remind the user that: 1) an inoperable door does not invalidate a successful performance of an overall air lock leakage l rate test, and 2) results of air lock testing will be evaluated l for impact on overall containment leakage rate requirements. The l (N remaining portions of the surveillance are relocated to the BasesCentainmentLeakageRateTc;tingProgramandareaddressedbyl a removal of detail change later in this section. No technical requirements are modified by these changes and they are considered administrative in nature. These changes are consistent with NUREG-1431 and the NRC guidance en the implementation for 10 CFR 50, Appendix J. Optien B. A.10 Four Notes are added to the Actions for CTS 3.6.3, " Containment Isolation Valves". N-tes 1, 3, and 4 provide guidance and clarification for the use of the TS. Note 1 allows for intermittent unisolation of an inoperable penetration flow path (s) under administrative controls consistent with CTS 4.6.1.1.a (see DOC L.31 for associated less restrictive changes). This is allowed for all penetration flow paths except containment purge valves for the lower compartment and instrument room. Note 3 requires the entry into the applicable Conditions and Required i Actions for systems made inoperable by an inoperable containment isolation valve. Note 4 requires the applicable Condition and Required Action of LC0 3.6.1, " Containment," to be evaluated, when an isolation valve leakage rate results in exceeding the overall l containment leakage rate. These two notes avoid misinterpretation d of the TS. No technical requirements are altered by these McGuire Units 1 and 2 Page A - 340 Supplement 25/20/97l
Discussien of Changas Stcticn 3.6 - C:ntainment Systems TECHNICAL CHANGES - LESS RESTRICTIVE volve under administrative controls when it is required to be closed or declared inoperable to comply with ACTIONS. This exception is necessary to establish a concept that although utilized, is not formally recognized in the present Technical Specifications. Without the allowance, necessary repairs and testing could not be performed and the equipment would not be able to be restored to OPERABLE status. This change is consistent with NUREG-1431. L.31 CTS 4.6.1.1.0 and on associated footnote allows certain containment isolation valves to be opened under administrative control. ITS 3.6.3 includes a note to the ACTIONS which provides on allowance to open any containment isolation volve required to be closed (except for the large containment purge / exhaust valves) under administrative controls. This is acceptable based on the administrative controls consisting of a dedicated operator at the valve in continuous conununication with the control room, or for valves with controls in the control room, a monitoring of containment isolation signal status. These controls provide protection equivalent to the automatic isolation system. The
&q large purge / exhaust volves are addressed by DOC L.30.
L.32 CTS 3.6.1.9 ACTION c requires restoring the inoperable valves to OPERABLE status. ITS 3.6.2 Required Action E.1 specifies isolating the offected penetration flow path by use of at least one closed and deactivated automatic volve, closed manual valve, or blind flange. The proposed change is a Less Restrictive change in that the CTS only allowed volve restoration to OPERABLE status, not penetration isolation. Isolating the offected penetration ensures the penetration flow path is performing its safety
- function and is on appropriate compensatory action. This change l is consistent with NUREG-1431.
L.33 CTS Surveillance Requirement 4.6.1.1.c contains details and l requirements for Type B leak rate testing for penetrations which l have been opened after testing. ITS SR 3.6.1.2 contains the broader requirement that all applicable Type B testing specified by 10 CFR 50, Appendix J, Option A must be met. The CTS requirement duplicates the requirements of 10 CFR 50, Appendix J, Option A section 111.0.2 which requires that Type B penetrations be retested following opening. This change is acceptable since it McGuire Units 1 and 2 Page L - 116 Supplement 25/20/97l l I
No Significant Hazards C$nsidIraticn S:ction 3.6 - Centainment Systems l LESS RESTRICTIVE CHANGE L.31 i The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outIined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.1.a and on associated footnote allows certain containment isolation valves to be opened under administrative control. ITS 3.6.3 includes a note to the ACTIONS which provides on allowance to open any containment isolation valve required to be closed (except for the large containment purge / exhaust valves) under administrative controls. This is acceptable based on the administrative controls consisting of a dedicated operator at the valve in continuous comunication with the control room, or for valves with controls in the control room, a monitoring of containment isolation signal status. These controls provide protection equivalent to the automatic isolation system. The large purge / exhaust valves are addressed by DOC L.30. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications l change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposed change allows containment isolation valves which are normally closed to be open under adminstrative control. The containment isolation valves are not assumed to be on initiator of any analyzed event. The isolation valves act to isolate the containment penetrations in the event of a design basis accident and ^ serves to limit the consequences of accidents. The proposed change still ensures the isolatton valves will perform their l required function and wiil serve to limit the consequences of ! design basis events as described in the UFSAR and that the results of the analyses in the UFSAR remain bounding. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated. O McGuire Units 1 and 2 Page 6263 of 6968 Supplement 25/20/97l t
N3 Significtnt H:zards C nsid:raticn I S2cticn 3.6 - Ccntainment Systems l l
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
l The possibility of a new or different kind of accident from any accident previously evaluated is not created because the proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant. l 3. Does this change involve a significant reduction in the margin of l safety? This change allows containment isolation valves which are normally closed to be opened under administrative control. The proposed change has been developed considering the importance of the containment isolation valves in limiting the consequences of a design basis event and thE concerns for the plants ability to perform required operational support functions with the necessary systems isolated. The proposed change allows for protection equivalent to that provided by an automatic isolation system. \ Considering the low probability of an event that would challenge l the containment boundary, the alternative protection provided by Q this change and the operational requirements to occasionally open G these volves, the proposed change is acceptable and any reduction in the margin of safety is insignificant. l I l I l l l l l O l l McGuire Units 1 and 2 Page 6366 of 6766 Supplement 25/20/97l
L I 1 McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems l O 3.6.3-5 DOC A.18 JFD 11 JFD Bases 5 CTS 4.6.1.1.a CTS 4.6.3.2 ITS SR 3.6.3.2 and Associated Bases ITS SR 3.6.3.3 and Associated Bases ITS SR 3.6.3.6 and Associated Bases CTS 4.6.3.2 is revised to include a clarification that valves which are locked, sealed, or
- otherwise secured in their required safety position are not required to be tested. CTS 4.6.1.1.a requires verifying that all penetration not capable of being closed by an OPERABLE automatic isolation valve and required to be closed during accident conditions are closed.
CTS 4.6.1.1.a becomes ITS SR 3.6.3.2 and ITS SR 3.6.3.3. Both of these ITS SRs and their associated Bases are revised per TSTF 45 to include a clarification that valves which are locked, sealed or otherwise securing in their safety position are not required to be verified closed. The CTS does not contain this provision. Therefore CTS 4.6.1.1.a needs to be revised to include this provision and the change designated DOC A.18. See Comment Number 3.6.3-6. Comment: Revise the CTS markup of CTS 4.6.1.1.a to include this Administrative change and revise DOC A.18 to discuss and justify this change to CTS
} 4.6.1.1.a.
DEC Response: The CTS markup and DOC A.18 are revised. l l l l t, mc3_cr_3 6 3.6-14 March 12, 1998 1
.speca m & g.c,.3 .
.. ~ .
h4.6 c0NTAIMENT SYSTEMS , , , 3/4.5.1 PRINARY CONTAlfetENT CONTAIMENT INTEGRITY LINITIIIG C0fcIT10N FOR OPERATION S et* AfirN y i
& 65 3.4. / 3.6.1.1 Primary CONTA! MENT INTEGRITY shall be usintained.
APPLICABILITY: MODES 1, 2, 3, and 4. *** l Ellgg: Without primary CONTA! MENT INTEGRITY, restore CONTAlfetENT INTEGRITY withia I bour or withis SWTDolet be in the at least NOT followtag stale 8Y within the next 6 hours and in COLD 30 hours. g,g SURVEILLANCE REOUIROIENTS jpg // .6.1.1 Primary CONTAlletENT INTEGRITY shall 6e demonstrated; l s/t 3.i,,3, @__ At least once per 31 days by verifyf ag that all . penetrations
- not
- c Se3.63.% whable of being closed by 0PERABLE containment automatic isolation /
ves or operator action during periods when valves are open under administrative control atainment Crequired isolation g closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions c. Q[t *8
.g $ S fenant at,{ m is la compliance with Soo M2fd'y After each clostag of each penetration subject to Type 8 testing, O g I I g 0'j except the containment air locks, if opened following a Type A or 8 test, by leak rate testfag the seal with gas at P . 14.8 psig, and verifying that iwhen the measurvd leakage rate for these seals is added to the leakage rates deteralmed perssant to Specification 4.6.1.2d. for all other Type 8 and C penetrattoes, the codined leakage rate is less than 0.60 L,. -
hh - st 3,6,3.@ *Except valves, blind flanges, and deactivated automatic k J ta 5 8 3.G.E< located inside the containment and the annulus andlare'1ocked, lvalvessealed otherwise secured la the closed posittoa. These penetratieasyshall be which $* 2 ' or are **h J l verified closed durfag each COLD SWTD0let except that such verification need not be performed more often than once per g2 days.
**The foil valves may seed on an in
,$ L tratt trol NC-14 - 42. WE-13 tient basi under admi -
-23. VK-34, , Fv-11 -13 ,
kone-time change is granted to have the contafament purge supply an exhaust isolation valves for the upper and lower compartment open in Modes 3 and 4 following the steam generator replacement outage. The cumulative time for having the valves open in Modes 3 and 4 is Italted to fourteen S d'63*4, g jy3 Mf) (14) days. All other provisions of this specification apply with the i exception of those containment purge valves open la Modes 3 and 4. Each ! ve will be sealed closed prior to faitial entry into Mode 2. McEUIRE - IAN!T 1 3/4 6-1 Amendment No.174 I pay & n O
i
. .. fwdhed$n 3.4 5 3/4.6 .
' CONTAIMDff SYSTEM _S 3/4.8.1 PRIMARY c0NTAI M Dff CONTAfIsdENT INTEGRITY SeeNerky 1.InritMs c0erTION FOR OPERATION N d / T5 5.4./ 3.6.1.1 primary CONTAIMENT INTEGRITT shall be maintained.
AppLICA81LITY: H00E3 1, 2, 3, and 4. *** EIIg: iffthout primary CONTAIMENT INTEGRITY, restore CONTA!WDff INTEGRI 1 bour or SHUTDOW bethe withis lafollowfag at least NOT 30 hours. STANDOT within the next 6 hours
~
$URVEfLUUICE REDUIREMDITS L.? Q.6.1.1
- primary CONTA1 MENT INTEGRITY shall be demonstrated: / !
fgpf //h '
/ q g* g At least once per 31 days by verifying that all pen valves or operator action during periods "y 5,c,,,g,g valves att open under adotaistrative control ontafament isolation' and required to be closed during accident condit{oas are closed by(vaim, idi,4 g flanges, or deactivated autamatic valves secured la their posittoas; Tb'.
4 specificatica 3.6.1.3; andBy verifylag that each containment air loc c. m 3" jfgY \\ After each clostag of each penetratiea' ~ subject t g j75 - O ,'4* 7 verifying that when the seasured leakage rate for.the added to the leakage rates determined pursuant to S 4 Qe.6.1.2d. j akage rate is for lessall thanother 0.60 L,.Type 8 and C penetrations, pecific - M. M *0'3' *Except valves, blind flanges, and deactivated c4 I g3,4,3'3@) located faside the containment and the annul tic valves which are ce *bNe ' otherwise secured in the closed position. These are locked, sealed or sere m9, verified closed during each COLD SHU1DOW except trationsishall-beg"
-need not be performed more often than once per g2 days.t such verification O(..M **Thetrative following control valves any be openee on an intermittent basis under adminis-f
' E-141. E-142, idE-13. WE-23, VK-34, VK-40 FW-11. FW-13 .
I
~,ec g u
***A one-time change is granted to have the containmen 7 3 and 4 following the steam generator replacement outage. The cumulative b j 15 M/ time for having the valves opea in Modes 3 and 4 is limited to fourteen (14) days. All other provistons of this specification apply with the exception of those containment purge valves open in Modes 3 and 4.
valve will be sealed closed prior to initial entry into Mode 2. Each)
/
McGUIRE - UNIT 2 3/46-1 Amendment No.156 O p.e 6 J la I l
l 1 Discussien of Changss { S;cticn 3.6 - Centainment Systems I tO ADMINISTRATIVE CHANGES O A.15 CTS 3.6.3 actions for penetration flow paths are separated into i actions for penetrations with two containment isolation valves l (ITS 3.6.3 Action A) and those with one containment isolation valve and a closed system (ITS 3.6.3 Action 0). Technical changes to these action requirements are discussed by other discussion of changes. This change is considered administrative and consistent with NUREG-1431. A.16 An action is added to CTS LC0 3.6.3 for two valves in a penetration flow path being inoperable. Currently, if two valves in a penetration flow path are inoperable, CTS LC0 3.0.3 would be required to be entered. The proposed Action provides a Completion Time of 1 hour to isolate the penetration. This time is the same allowed by CTS LC0 3.0.3 before a power reduction is required. This change also allows all isolation valve Actions to reside in one specification. No technical readirements are modified by these changes. These changes, retained in ITS 3.6.3, are administrative in nature and are consistent with NUREG-1431. p A.17 CTS 3.6.3 Action e, providing an exception to CTS Specification d 3.0.4 if the affected penetration is isolated and the associated system is declared inoperable, is deleted. This exception is no longer required because the Actions require any inoperable penetration to be isolated and allows continued operation which is consistent with the requirements of LC0 3.0.4. The requirement to declare the associated system inoperable is addressed by a note to the actions. LC0 3.0.4 does not allow MODE changes when the LC0 is not met except when LC0 3.0.4 is exempted or if the Actions to be entered allow continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This change is administrative because no technical requirements have been changed. This change is consistent with NUREG-1431. A.18 CTS Surveillance Requirement 4.6.3.2, 4.6.1.1.a, and 4.6.2.c are l l revised to include a clarification that valves which are locked, l sealed or otherwise secured in their required safety position, are not required to be tested. The proposed requirement does not l change the technical content or validity of the required testing. Therefore, the change is considered administrative in nature. O 0 l l McGuire Units 1 and 2 Page A - 57 Supplement 25/20/97l l
Discussien of ChInges Szctien 3.6 - C:ntainment Systems ADMINISTRATIVE CHANGES These changes, retained in ITS SR 3.6.3.76, 3.6.6.3, 3.6.3.3 and 3.6.36.4, are consistent with NUREG-1431. A.19 CTS LCOs 3.6.3 and 3.6.1.9 are being combined into ITS LC0 3.6.3," Containment Isolation Valves". The two CTS LCOs duplicate the requirements for the valves used for containment penetration flow path isolation. Since the wording of CTS LC0 3.6.1.9 is repeated in the Action, it is eliminated. Minor wording modifications are made in combining the LCOs, but these changes do not alter the technical requirements. This change is considered administrative and is consistent with NUREG-1431. A.20 Not used. CTS 3.5.1.0 ^ction c requirc; inoperable valve; be re;tcred to OPEP^SLE statu; <ithin 21 heur;. ITS 3.5.3 fction E require; the same valve; t0 be i;clated by u;c cf at lea;t onc l cic;cd and de activated automatic valve, cle cd manual valve, or blind flange. !;clating a containment penetration valve ensure; the valve i; perfcrming it', cafety function and i; an appropriate compen;atory action. Thi; change i; con;idered an aamini;trative shange and i; cen;istent with NUREC 1431. A.21 Not used. A.22 CTS 4.6.2.c.3 and 4.6.5.6.2 require that system functions in response to the Containment Pressure Control System (CPCS) be verified. CTS 4.6.5.6.1.f refers to a required start permissive signal for hydrogen skimers but does not state the source. ITS 3.6.6, 3.6.8, and 3.6.11 surveillance requirements provide the specific requirements to be verified and refer to the start , permissive and terminate signals of the CPCS. The setpoints are i already specified in CTS 3.3.2 and retained in ITS 3.3.2. This 1 change does not alter any surveillance requirements and is therefore considered an administrative change. A.23 Not used. A.24 CTS LC0 3.6.1.8 Action b allows the ventilation system heaters to be inoperable up to 7 days and allows continued operation of the system provided a report is made to the NRC within 30 days. The report is required to state the reason for the inoperability and i the planned actions to return the heaters to operable status. l This allowance is reformatted and retained as ITS 3.6.10 Action B. ! l McGuire Units 1 and 2 .Page A - 67 Supplement 25/20/07l !
)
i McGuire & Catawba Improved TS Review Coments ITS Section 3.6, Containment Systems l t 1 3.6.3-6 DOC A.18 l l JFD 11 JFD Bases 5 CTS 4.6.1.1.a STS SR 3.6.3.3 and Associated Bases STS SR 3.6.3.4 and Associated Bases l ITS SR 3.6.3.2 and Associated Bases ITS SR 3.6.3.3 and Associated Bases l STS SR 3.6.3.3 and SR 3.6.3.4 verify the position of containment isolation manual valves and ) blind flanges outside and inside containment respectively. The SRs are modified to include a clarification that valves which are locked, sealed or otherwise secured in their required safety position are not required to be verified in their closed position. This modification is in accordance with TSTF-45 which is acceptable. However, the Bases changes are not in accordance with TSTF-45. Comment: Licensee to update submittal to be in accordance with TSTF-45 or provide adriitional justification for the deviations. j DEC Response: The typed ITS Bases is consistent with TSTF-45, however, the markup of the STS Bases O inadvertently shows the TSTF-45 change inserted at the wrong paragraph. The STS markup I has been corrected to be consistent with TSTF-45 and the typed ITS Bases. Additionally, it was discovered that the translation from CTS to ITS did not include valves located in the annulus as part of the population of valves excluded from the more frequent surveillance. j This has been added to ITS SR 3.6.3.3 and ITS 3.6.3.4 consistent with CTS 4.6.1.1 and the ' associated footnote, I l l - A mc3_cr_3.6 3.6-15 March 12, 1998 l i l I
Containment Isolation Valves 3.6.3 k/ SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I l SR 3.6.3.1 Verify each containment purge valve for the 31 days lower compartment and instrument room is sealed closed, except for one purge valve in a penetration flow path while in l Condition E of this LCO. T SR 3.6.3. -------------------NOTE-------------------- 1 ( Valves and blind flanges in high radiation areas may be verified by use of administrative controls. Verify each containment isolation manual 31 days valve and blind flange that is located y 3 outside containmentyand not locked, sealed, McF or otnerwise secured and required to be J closed during accident conditions is closed, except for containment isolation O valves that are open under administrative controls. . SR 3.6.3. -------------------NOTE-------------------- Valves and blind flanges in high radiation i areas may be verified by use of administrative controls. Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 insiria enntainmantYand not locked, sealed, from MODE 5 if or otherwise secured and required to be not performed f closed during accident conditions is within the closed, except for containment isolation previous valves that are open under administrative 92 days controls. (continued) o McGuire Unit 1 3.6-12 W Js9Q 2-
l l i ! I Containment Isolation Valves 3.6.3 ! l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY j SR 3.6.3.1 Verify each containment purge valve for the 31 days j lower compartment and instrument room is j sealed closed, except for one purge valve l in a penetration flow path while in l Condition E of this LCO. 1 I
/M5 _ 7 l
SR 3.6.3. -------------------NOTE-------------------- ! Valves and blind flanges in high radiation i areas may be verified by use of administrative controls. l Verify each containment isolation manual 31 days valve and blind flange that is located outside containmentYand not locked, sealed, f or otherwise secured and required to be closed during accident conditions is or closed, except for containment isolation l
/ a,nte valves that are open under administrative l \ controls.
SR 3.6.3. -------------------NOTE-------------------- Valves and blind flanges in high radiation areas may be verified by use of administrative controls. Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 inside containmentfand not locked, sealed, from MODE 5 if I or otherwise secured and required to be not perfonned I ,
. closed during accident conditions is within the closed, except for containment isolation previous valves that are open under administrative 92 days !
controls. l (continued) ! l l lO McGuire Unit 2 3.6-12 8US/ t/20/97-
Containment Isolation Valves I B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3 1, REQUIREMENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been performed. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the tenn " sealed" has no connotation of leak tightness. The Frequency is a ; result of an NRC initiative, Generic Issue B-24 (Ref. 4), ' related to containment purge valve use during plant operations. In the event purge valve leakage requires entry , into Condition E, the Surveillance permits opening one purge valve in a penetration flow path to perform repairs. l O I*J btT G . t SR 3.6.3.83) l This SR requires verification that each containment isolation manual valve and blind flange located outside containment 1and not locked, sealed, or otherwise secured and
" * " )) required to be closed during accident conditions is closed.
The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Ratherm it involves verificatioryhroughCiniacranve soffthis, such@ a l system walkcown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR , specifies that containment isolation valves that are open under administrative controls are not required to meet the l SR during the time the valves are open. This SR does not (continued) McGuire Unit 1 B 3.6-24 M*W -5/20/97 - l
l l Centainment Isolation Valves B 3.6.3 ! BASES (continued) SURVEILLANCE SR 3.6.3 continued) REQU8REMENTS apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high l radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. i Therefore, the probability of misalignment of these containment isolation valves, once they have been verified . to be in the proper position, is small. ) SR 3.6.3. This SR requires verification that each containment isolation manual valve and blind flange located inside Ge_ containmentiand not locked, sealed, or otherwise secured and I i i g uS - required to be closed during accident conditions is closed. l l The SR helps to ensure that post accident leakage of l
) radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering N0DE 4 from H0DE 5 if not performed within the previous 92 days" is appropriate since these containme ,
isolation valves are operated under administrative co W ols and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. , (continued) McGuire Unit 1 B 3.6-25 bg/ML5/20/92
I i Centainment Isolaticn Valves B 3.6.3 O' BASES (continued) SURVEILLANCE SR 3.6.3.1 REQUIREENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been perfonned. Therefore, these valves are required to be in the sealed closed position during NODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance pennits opening one purge valve in a penetration flow path to perform repairs. N O SR 3.6.3.@ - j l This SR requires verification that each containment isolation manual valve and blind flange located outside ora E W containmentyand not locked, sealed, or otherwise secured and l required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve annipulation. Rather, it invol_ves verificationthrough dMn=rmve c-uuN -n as a l l system walkdown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative contrils are not required to meet the SR during the tinu the valves are open. This SR does not (continued) McGuire Unit 2 8 3.6-24 pg6W ';/20/W
Centainment Isolation Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3 continued) REQU8REMENTS apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically
- restricted during MODES 1, 2, 3 and 4 for ALARA reasons.
Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. SR 3.6.3. This SR requires verification that each containment isolation manual valve and blind flange located inside g Q Q containm yeand not locked, sealed, or othentise secured and required to be closed during accident conditions is closed. O The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. (continued) McGuire Unit 2 B 3.6-25 g t_. 5/20/97-
4 Containment Isolation Valves f ar- -- - _a EJhmt=ns_pheh we o ------3r 15 oual) l (4s.ta,<n,waap e inShu.oeseaf room f Y SURVEILIANCE REQUIRBGMTS l SURVELLTANCE yREQUENCY wk.mmcod) _ 3.6.3.1 Verify each 6 purge valvekis sealed 31 days closed, except for one purge valve in a y R penetration flow path while in Condition E h of this 140. hgd Md f 5*lt , ) (Ca nia W T) - r(~ SR 3.6.3.2
.6 .
(A Perv W% .r) each((8F inc) purge amps closed, J1
-3 1
except - tha uni -- -- :- r t puto6 , valves are open sure control, l NI ' ALARA or air quality ' - -ations for
\/f personnel entry, or for Surve ire the valves to be open.
u SR 3.6.3 mrz }
< valves and blind flanges in high radiation areas may be verified by use of administrative controls.
e verify each containment isolation manual 31 days valve and blind flanoe that is located outside containmenbfand required to be ~ f0"g T tale",'pg E*e g # closed during accident canditions is
- O h M IM3 o%edo FW'jJ i
closed, except for containment isolation l l valves that are open under administrative I controls. (contim M ) l wee-696- 3.6-12 Rev 1, 04/07/95 M kth O O
)
i 1
. 1 1
l ract Containment muu.t ---- --- Isolation k L - 4valves
- rwr,y== 4 m J= L 3.6.3 SINtVEILLANCE REQUIRINGBrrS (continued)
SURVEILIANCE yREQUENCY SR 3.6.3 %JTE k valves and blind flanges in high radiation j areas may be verified by use of I alg administrative h j Verify each containent isolation manual Prior to I g valve and blind flange that is located entering MODE 4 j O M M *I I e insice containmenSyand required to be frca MODE 5 if i 531,J , . " - closed during accident conditions is not performed i
'o w , w cc seco<<E closed, except for containment isolation within the j valves that are open under administrative previous 4 controls. 92 days I Nb Verif y N J
'{
SR 3.6.3.[ "^1= H = H e M 6k @ In . bte@each autcoatiPoontainment accordance isolation valve is within limits. with the
/
Inservice Testing
;r
/4 h
, - - - . - ._ _,_ -~ --
_SR3.6.3.(
- Cy e each weight or spring 1 check 92 days Ive testable during operati one complete cycle of full 1, and verify enda M valve closed when / M the differential pressure the direction W ,
of flow is s [1.2] paid opens when the i differential pre.sure the direction of j flow is t (1.2] psi < (5.0) psid.
- ~./ I 1
(Continued) l l l 1 1 j 1 ifee-STe- 3.6-13 Bev '., 04/07/95 l ma-c . l
f I l l l I r Q l Containment Isolation ValvesJ Atmosphecic) Q
- oubatmossnerie- ira -ne and & alJ
~
L if 3.6.3 BASES i SURVEILLANCE SR 3.6.3 j i REQUIREMENTS l (continued) This SR requires verification that each containment I isolation manual valve and blind flange located outside contairnentfand required to be closed during accident conoitions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testino or valve manipulation. Rather./b!. .sla)k it involres verificationvthrough a system walkdowng that 3 those containment isolation valves outside containment anore~Q, c..,.s
,q,-d f capable of being mispositioned are in the correct position. (s4.w :,,y,g
,cnn & ! Since verification of valve position for containment isolation valves outside contairnent is relatively easy, the 31 day Frequency is based on engineering judgment and was h
chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are ggh y /adek' open under administrative controls are not required to meet the SR during the time the valves are open. Q yset Q O b'5 ' 'ff"" The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified
\. closed by use of administrative means. Allowing verification by administrative means is considered
acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. y p% " Y SR 3.6.3. q This SR requires ve ification that each containment isolation manual valve and blind flange located inside contaiJnment 'and required to be closed during accident conoitions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or cases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of ' prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days' is appropriate since these containment isolation valves are operated under l l (continued) W0c STS B 3.6-40 Rev 1, 04/07/95 NL61ue&
O ContainmentIsolationValvesptmos 3 csuoatmn.nneric. ice um-nser. a
.3 BASES D
SURVEILLANCE SR 3.6.3. continued) REQUIREMENTS adninistrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open.j b hay-
\ This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of adninistrative means. Allowing verification by adninistrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probabilit misalignment of these containment isolation valves,once y of the have been verified to be in their proper position, is t y @ '*' D g) I SR 3.6. 3.'
Verifying that the isolation time of eachraower operat_ed@ ' automatic,4 containment isolation valve is within limits is h
- required to demonstrate OPERABILITY. The isolation time test ensures the valve wili isolate in a time period less g setti kR than or equal to that assisned in the safety enalyses. (The 'g -ptE U isolation tiswDand frequency of this SR are in accordance gU with the Inservice Testing Program (r pz ers .t.
r --- SR 3.6.3.M
-\
In suba spheric containments, the check val s that serve a conta t isolation function are weight spring loaded to prov de positive closure in the directi of flow. This ensur that these check valves will remai closed when the /:El insi containment atmosphere returns to teospheric W c 'tions following a DBA. SR 3.6.3.6 quires ve fication of the operation of the c k valves that are t table during unit operation. The Fr of 92 days is sistent with the Inservice Testing rogram requirement or valve testing on a 92 day Frequ y. _ (continued) M9(HiM- B 3.6-41 Rev 1, 04/07/95 ddtu[fD
McGuire & Catawba Improved TS Review Counsents i ITS Section 3.6, Containment Systems 3.6.3 DOC A.20 CTS 3.6.1.9 ACTION c ITS 3.6.3 RA E.1 CTS 3.6.1.9 ACTION c requires restoring the inoperable valves to OPERABLE status. RA E.1 specifies isolating the affected penetration flow path by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange. The proposed change has been categorized as an Administrative change. The proposed change is a Less Restrictive change in that the CTS only allowed valve restoration to OPERABLE status, not penetration isolation. Comment: Revise the CTS markup to show this change as a Less Restrictive change and provide the appropriate discussion and justification. DEC Response: The CTS markup has been revised to reflect new DOC L.32 to justify this change. O - 1 i i l mc3_cr_3.6 3.6-16 March 12, 1998
TpcCth 3 h' r. i.6,3 l O
- CONTAINNENT
' CONT EMS VENTILATION T
.) I /LINITINGCONDITIgOPERATION c i 3.6.1.9 Ea ontainment purge s y and/or exhaust is ationvalveshallbe]
1 s.n =
- # e "*='.c Each contafament Iouer coupe rye t(241 Iy and/or e and inst st isolation valve for the )
t room (12.lach and 24 j. ach)skal sealed c1 . and 3 upper rtment y be r
- rios a c -
- waaerprovided JBo more than engrpair (one supply) iand opt exhaust)/tt open at omg timef APPLICABILITY: , MODES 1. 2. 3. and 4 l
==
a. GD any contal t purge supply a or exhaust is ton valve r lower c t or inst room open or sealed c1 ed A c % dit A / close ana/or seas closed that valve or isolate the penetration s _4 Chb M~ within 4 hours. otherwise be la at least HDT JTAW8T within the next 6 hours and in C0la SHlff00ldi within the following 30 hours. I
- b. With .ontalament putye s and/orexhaustisolati valve for upper compartment for more than 250 hours ring a d'o cal r year, close any valve or isolate the I O 'l la 4 hours, otherwl hours, and la COLD la at least NOT ST within the followi tration(s) within the next 30 hours.
l ACWbb [. With a contaissent parte supply and/or exhaust isolation valve 's A./
~ havina a m!asured 1**=
~
rate la eJa ess of the Itaits 6L8a C cs-4.6.: a nere tae dtroperab W va'se%d'o7 therwise be la at least nut 5"AW5Y wiitta next 6 hours, and in COLD within the A l4
%N f8118*18930 hours.) mcett la g, 3 t.g ~
isolete vk $fuS ['f t. Y Y/ daht, c(ned MmIwAw,orsb& sde 1 Plame. s f h*Aone-time is granted to have containment purge supply a or exhaust i ation valves for the r and lower compartment open Modes 3 and 4 11owing the steam gener r replacement outage. The lative Jj time f havlag the valves open days Modes 3 and 4 is limited t ourteen(14) All other provisions of is specification apply wi the exception of se containment putte v ves open in Modes 3 and 4 ch valve will be s led closed prior to int al entry into Mode 2.
' McGuiltE UNIT 1 3/4 6 13 Amendment No. 174 page ? J l2
fjf?!,Y'Jbbit S.fr.3 , O ' CONTA SYSTDtS teseENT VENTI TION SYSTm MfTING ON FOR 10N) C3.E.1.g Each con ament purge y and/or exhaust i ation valve sha be
; ja ./
M LE and
' a. containment s ly and/or aust isolation val for the rc rtmes 24-in and ins at roca (12-inch 24-tech) ska 1 be es ed closed,
~
f . 6. The sai. . v. supp for
% upper al_ ,
a t(2 inc wear =8 d r exhau[d forAn hour w be egrene toisolatidvalv u ng more one pa (one spJ h,./ "V.e peavstyre get i.e. _ APPLICA4 RIH: fm0E5 1, 2, 3, and 4 @ sue - i ladre r ed close and/or seal closed t t valve or isolate the penetration s 4Cll'd 4'I within 4 hours, otherwise be in at least NOT STAND 8Y within the next Ach % # 6 kours and in COLD SHUT 00WN within the following 30 hours,
- b. Withthycontainmentpurge upply and/or exhaust olationvalve(
for W upper compartsen open for more than hours during a cal 3r wear valve or isol the penetration ) O
- la4 hours,,close hours, and in othe se la at least within t STANDBY withis ollowing 3d hours next
- c. With a containment purge supply and/or exhaust isolation _ valve (sl having a seasured leakage rate in excess of the limit <Coj.56erM,sG cf3l Ilia 4.na.v. spor sco.a.rf.4,Giistere the inoperable valve (sc to))' p,fg git llABLE,Maestwitata Z4 hours, otherwise De in at least NOT
$TAICST witnin(the next 6 hours, and la COLD SHUT 00688 within the
'* M
)!! serf /3 g
p w tre/4 / W b {.Y 7 e huse of et feed Mada/ /&Y
,,4mi
Apos-ses- 3.6-8 Rant 1, 04/07/95 M auFG l
i } Justificatien fer D;viatiens l Sectien 3.6 - R: fueling Optratiens O V TECHNICAL SPECIFICATIONS
- 10. The changes are consistent with generic change TSTF-17 to NUREG-1431 provided to NRC by the industry owners groups, except that an 18 month frequency, consistent with the current refuel cycle is proposed.
- 11. The changes are consistent with generic change TSTF-45 to NUREG-1431 provided to NRC by the industry owners groups.
- 12. The changes are consistent with generic change TSTF-30 to NUREG-1431 provided to NRC by the industry owners groups.
- 13. Not used.The containment upper ccmpartment purge valve; are automatic valve; chich are closed by a containment i;chtien signal. Only manual valves and *he containment 10wer compartment and instrument recm purge valve; are currently required to be verified closed once per 31 days, therefore, the station i; not electing to add the NUREC SR 3.6.3.2 more restrictive requirement te verify that automatic containment ischtica valve; are cle;cd.
_ 14. The NUREG SR 3.6.19.4 requirement to verify the system flowrate during the negative pressure test of the reactor building annulus is deleted. Verification of flow rate is done by taking traverse measurements of the duct work and cannot be done in the short amount of time required to j verify the negative pressure. This requirement is not in the current TS and is not adopted in the proposed SR 3.6.16.2. System flowrates are , verified during testing required by the Ventilation Filter Testing l Program. 1
- 15. The changes are consistent with generic change TSTF-46 to NUREG-1431 provided to NRC by the industry owners groups.
- 16. STS 3.6.3 Required Action A allows check valves to be used to isolate on inoperable containment isolation volve. During development of the initial draft STS by the industry and NRC, the proof and review version of the STS required that the check volves be located inside containment. The industry provided coments (June 1991) which suggested that the words "inside containment" be removed since some plants were licensed prior to l
the issuance of the 10 CFR 50 Appendix A General Design Criteria. The GDC does not allow use of a check valve outside containment for containment isolation. The reason provided by the industry for the requested change is not applicable to McGuire or Catawba. Therefore, ITS 3.6.3 is proposed f consistent with the current licensing basis to require the check valve be 1 %. inside containment before it con be credited as an isolation device. l l McGuire Units 1 and 2 22 Supplement 26/20/W l l
McGuire & Catawba Improved TS Review Conenents ITS Section 3.6, Containment Systems 3.6.3-9 DOC L.9 JFD 13 JFD Bases 3 (McGuire) , JFD Bases 5 (Catawba) STS 3.6.3.2 and Associated Bases CTS 3.6.1.9.b for McGuire requires the containment purge valves for the upper containment be closed except for up to 250 hours per calendar year provided no more than one pair are open at a time. CTS 3.6.1.9.b for Catawba requires the containment air release and addition system purge valves to be closed except for up to 3000 hours per calendar year for pressure l control, for ALARA, and respirable air quality considerations for personnel entry and for surveillance tests that require the valve to be open. CTS 3.6.1.9 ACTION b and 4.6.1.9.2 are the associated remedial measures and surveillance for this LCO. None of these requirements is retained in the ITS, and the deletion is justified by DOC L.9. The staff finds this unacceptable. CTS 4.6.1.9.2 for both McGuire and Catawba verifies that these particular purge valves are closed by verifying the cumulative time the valves are open on a 7 day l frequency. The staff finds that for CTS 4.6.1.9.2, STS SR 3.6.3.2 is the equivalent ITS SR for these valves, and that STS/ITS ACTION A.1 is the equivalent remedial measure to take when the CTS requirements are not met. Also see Comment Numbers 3.6.1-3 and 3.6.3-1. Comment: Revise the ITS submittal to include STS SR 3.6.3.2 or a revised STS SR 3.6.3.2 that conforms to the CTS requirements. Revise the CTS submittal accordingly. Provide the O appropriate discussions and justification to support these changes. DEC Response: The ITS, CTS markup, and STS markup have been revised to show the addition of the surveillance requirement in lieu of the existing time limit for these valves. DOC L.9 has been revised to reflect these changes. The ITS, CTS markup, and STS markup are renumbered accordingly, i mc3_cr_3.6 3.6-16 March 12, 1998
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE l FREQUENCY SR 3.6.3.1 Verify each containment purge valve for the 31 days lower compartment and instrument room is sealed closed, except for one purge valve in a penetration flow path while in Condition E of this LCO. SR 3.6.3. h -------------------NOTE-------------------- { Yalves and blind flanges in high radiation areas may be verified by use of administrative controls. Verify each containment isolation manual 31 days valve and blind flange that is located y outside containmentyand not locked, sealed, 93 or otnerwise secured and required to be closed during accident conditions is s closed, except for containment isolation valves that are open under administrative A controls. A SR 3.6.3. -------------------NOTE-------------------- Valves and blind flanges in high radiation areas may be verified by use of administrative controls. i Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 insida enntainmantYand not locked, sealed, from MODE 5 if or otherwise secured and required to be not performed f closed during accident conditions is within the closed, except for containment isolation previous valves that are open under administrative 92 days controls. (continued) !O l McGuire Unit 1 3.6-12 Sqpd 2- W
Specification 3.6.'3 O INSERT I SR 3.6.3.2 Verify each containment purge and exhaust 31 days j isolation volve for the upper compartment is closed, except when the volves are open for l pressure control, Al. ARA or atr quality l considerations for personnel entry, or for 1 SurvetIlances that require the valves to be open. l 1 O ' l McGuire Page of
l Containment Isolation Valves 3.6.3 e l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY I l SR 3.6.3.h Verify the isolation time of automatic In accordance l power operated containment isolation valve with the is within limits. Inservice Testing Program SR 3.6.3. h Perform. leakage rate testing for 184 days \ containment purge lower and upper compartment and Instrument room valves with A_M , resilient seals. within 92 days after opening the valve l SR 3.6.3.M Verify each automatic containment isolation 18 months valve that is not locked, sealed or otherwise secured in position, actuates to p)- the isolation position on an actual or simulated actuation signal. SR3.6.3.4 ------------------NOTE------------------- ------NOTE----- l Penetrations not individually testable SR 3.0.2 is not l shall be determined to have no visible applicable. leakage when tested with soap bubbles. ---------------
----------------------------------------- In accordance with 10 CFR 50 Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P , 14.8 approved psig. m exemptions b
'g ., a % .y lu kil,e j
%hb4 AuD Dudn3 % 5.kt \ l T p A les h L l Peae b b' w m b
'n ik6v&ahksdt. { V McGuire Unit 1 3.6-13 J pph - Q 5/20/^7 l
Containment Isolation Valves 3.6.3 l (U SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each containment purge valve for the 31 days lower compartment and instrument room is sealed closed, except for one purge valve in a penetration flow path while in Condition E of this LCO. t
/45 )
SR 3.6.3. -------------------NOTE-------------------- ! Valves and blind flanges in high radiation ; areas may be verified by use of ' administrative controls. Verify each containment isolation manual 31 days valve and blind flange that is located outside containmentfand not locked, sealed, f or otherwise secured and required to be closed during accident conditions is or closed, except for containment isolation
\ a ankt valves that are open under administrative l controls.
SR 3.6.3. -------------------NOTE-------------------- Valves and blind flanges in high radiation areas may be verified by use of administrative controls. Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 inside containmentfand not locked, sealed, from MODE 5 if I or otherwise secured and required to be not performed 3 closed during accident conditions is within the closed, except for containment isolation previous valves that are open under administrative 92 days control s. (continued) O McGuire Unit 2 3.6-12 84/ -5/2G/47--
Specification 3.6.3 6 O INSERT SR 3.6.3.2 Verify each containment purge and exhaust 31 days isolation volve for the upper compartment is closed, except when the valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. l l l 1
- O I
l
Containment Isolation Valves 3.6.3 1 SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY 1 l SR 3.6.3.@ Verify the isolation time of automatic In accordance ! i power operated containment isolation valve with the is within limits. Inservice
- Testing Program l SR 3.6.3.h Perform leakage rate testing for 184 days l containment purge lower and upper l compartment and Instrument room valves with MQ l resilient seals.
within 92 days after opening the valve SR 3.6.3.h Verify each automatic containment isolation 18 months k valve that is not locked, sealed or ; otherwise secured in position, actuates to O the isolation position on an actual or simulated actuation signal. . SR 3.6.3. d ------------------NOTE------------------- ------NOTE----- Penetrations not individually testable SR 3.0.2 is not shall be determined to have no visible applicable. leakage when tested with soap bubbles. ---------------
----------------------------------------- In accordance with 10 CFR 50, Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P., 14.8 approved psig. q exemptions;f.c dand \ T3rty. 4uldtt f%e. Wt**
b"E 0% sa 3.t.i.i Tyg A ksh L.
% % nd an6(3 am O
McGuire Unit 2 3.6-13 Jurfb d t-5/20/^7- <
T Contr.inment Isolation Valves B 3.6.3 BASES ACTIONS C.1 and C 4 (continued) administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. D_d With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours. Restoration can be accomplished by isolating the penetration (s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed g to be the lesser actual pathway leakage of the two devices. 5 The 4 hocr Completion Time is reasonable considering the time required to restore the leakage by isolating the
~
penetration (s) and the relative importance of secondary containment bypass leakage to the overall containment function. l' E.1. E.2. and E.3 In the event one or more purge valves for upper and lower containment or instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. A valve with resilient seals utilized to satisfy Required Action E.1 must have been demonstrated to meet the leakage requirements of SR 3.6.3.[. h The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist. (continued) McGuire Unit 1 B 3.6-22 gg(pML 6/20/9T'
Containment Isolation Valves B 3.6.3 BASES ACTIONS E.1. E.2. and E.3 (continued) In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve maniDulation. Rather. it involves verificatio through afEinistfDNe mtA sdED
@ a system walkdown@or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
For the containment purge valve with resilient seal that is
~ isolated in accordance with Required Action E.1, SR 3.6.3.
must be perfonned at least once every 92 days. This assures that degradation of the resilient seal is detected and confinns that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. i (continued) I McGuire Unit 1 B 3.6-23 JvppkJ E/20/97
T Centainment Isolation Valves B 3.6.3 f ( ' BASES (continued) ! SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demon:trate their ability to close during a LOCA in time to limit offsite doses has not been performed. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant ! operations. In the event purge valve leakage requires entry into Condition E, the Surveillance permits opening one purge valve in a penetration flow path to perform repairs. O v 1eJ 56AT SR 3.6.3.83) l This SR requires verification that each containment isolation manual valve and blind flange located outside containment 1and not locked, sealed, or otherwise secured and 0" )1 required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verificatiog)through GGliiiint>crau ve r,efftrols._such@ a j system walkcown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day l Frequency is based on engineering judgment and was chosen to i provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not l l (continued) McGuire Unit 1 B 3.6-24 D W i/20/97-1 l l
l ((T INSERT ' Q) SR 3.6.3.2 This SR ensures that the containment purge supply and exhaust isolation l valves for the upper compartment are closed as required or, if open, open for an allowable reason. If a valve is open in violation of this i SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. The SR is not required to be met when the valves are open for the reasons stated. The valves may be opened for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other l containment isolation valve requirements discussed in SR 3.6.3.3. 'O l l o
Containment Isolation Valves B 3.6.3 l R BASES (continued) L SURVEILLANCE SR 3.6.3 continued) REQU8REMENTS apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, seating, or securing. The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. SR 3.6.3.h This SR requires verification that each containment isolation manual valve and blind flange located inside er containmentland not locked, sealed, or otherwise secured and I pulus required to be closed during accident conditions is closed. l O The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not perfonned within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access l to these areas is typically restricted during MODES 1, 2, 3, and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. (continued) McGuire Unit 1 8 3.6-25 bg/M ' 5/20/91
Containment Isolation Valves B 3.6.3 O BASES (continued) SURVEILLANCE SR 3.6.3 1 REQUIREMENTS (continued) Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program. SR 3.6.3.5h , For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, is required to ensure OPERABILITY. The measured leakage rate for containment purge lower compartment and instrument room valves must be s 0.05 L, when pressurized to P,. The measured leakage rate for containment purge upper compartment valves must be s 0.01 La when pressurized to P,. Operating experience has O demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining { this penetration leak tight (due to the direct path between containment and the environment) a Frequency of 184 days was established. l 1 The containment purge upper compartment valves may be used 4 during normal operation, therefore, in addition to the 184 day Frequency, this SR must be performed every 92 days after opening the valves. The 92 day Frequency was chosen ; recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened. The containment purge lower compartment valves and instrument room valves remain closed during normal operation and this SR is only perfonned every 184 days for these valves. (continued) McGuire Unit 1 B 3.6-26 1 p h > 6/20/ d
Containment Isolation Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3. 6. 3.N REQUIREMENTS l (continued) Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when ) performed at the 18 fronth Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.6.3.d \, This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse cf the two isolation valves) unless the penetration is isciated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J maximum pathway leakage limits are to be quantified in accordance with Appendix J). Penetrations which are not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurize The Frequenc s required by 10 CFR 50, i Appendix J, as modified by approved exemptions (and dud $ $g.3,4,1,b P N '4
- Th A bSS -
kNf (continued) McGuire Unit 1 B 3.6-27 SuppladL-6/E0/97 -
Centainment Isolatien Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3 (continued) REQUIREMENTS l therefore, the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J. Typ C test. This SR simply imposes additional acceptance criteria. 6 .- Bypass leakage is considered part of L,. REFERENCES 1. UFSAR, Section 15.
- 2. 10 CFR 50.36. Technical Specifications, (c)(2)(it).
- 3. UFSAR, Section 6.2.
- 4. Generic Issue B-24.
- 5. Standard Review Plan 6.2.4.
~
O O McGuire Unit 1 B 3.6-28 Surp h q gjgg/
Containment Isolation Valves B 3.6.3 ! BASES ACTIONS C.1 and C.2 (continued) administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. Ed With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours. Restoration can be accomplished by l 1solating the penetration (s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are ; used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. O D The 4 hour Completion Time is reasonable considering the ' time required to restore the leakage by isolating the l penetration (s) and the relative importance of secondary containment bypass leakage to the overall containment function. ! E.1. E.2. and E.3 In the event one or more purge valves W upper and lower containment or instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to withir, limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. A velve with resilient seals utilized to satisfy Required Action E.1 must have been lo i demonstrated to meet the leakage requirements of SR 3.6.3. . The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment dnes not exist.
/
b] (continued) McGuire Unit 2 B 3.6-22 JWyU
- SW
Containment Isolaticn Valves B 3.6.3 BASES , l ACTIONS E.1. E.2. and E.3 (continued) In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic I basis. The periodic verification is necessary to ensure i that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it involves verificatiogthrough qtgminuw Uveonuvi>P51IEt>
@ a system walkdown or computer status indication, that those isniation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days' is based on engineering judgment and is consider 6d reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
For the containment purge valve with resilient seal that is isolatedinaccordancewithRequiredActionE.1,SR3.6.3.d l must be perfonned at least once every 92 days. This assures that degradation of the resilient seal is detected and confinns that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least. MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) McGuire Unit 2 8 3.6-23 Svpp h W s/2G/97
I Centainment Isolaticn Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3.1 REQUIREENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been perfonned. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed nnst have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the tenn " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance pennits opening one purge valve in a penetration flow path to perform repairs. O n SR 3.6.3.M - l This SR requires verification that each containment
= isolation manual valve and blind flange located outside containmentyand not locked, sealed, or otherwise secured and (or ansk required to be closed during accident conditions is closed.
l The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it invol_ves verificatiogthrough dMnweuve -uk -n n a g system walkdown or conputer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in ti.e correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not (continued) McGuire Unit 2 B 3.6-24 gQ% 1/20/^7~
INSERT SR 3.6.3.2 1 1 ! This SR ensures that the containment purge supply and exhaust isolation valves for the upper compartment are closed as required or, if open, open for an allowable reason. If a valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not l considered to have leakage outside of limits. The SR is not required to l be met when the valves are open for the reasons stated. The valves may be opened for pressure control, ALARA or air quality considerations for personnel entry, or for.Surveillances that require the valves to be ! open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of tiine. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.3. 1 O I t l l
Containment Isolation Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3 continued) REQU8REMENTS apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing , verification by administrative means is considered i acceptable, since access to these areas is typically
- restricted during MODES 1, 2, 3 and 4 for ALARA reasons. I Therefore, the probability of misalignment of these containment isolation valves, once they have been verified ,
to be in the proper position, is small. ! SR 3.6.3. This SR requires verification that each containment l isolation manual valve and blind flange located inside g y Q containm geand not locked, sealed, or otherwise secured and regmred to be closed during accident conditions is closed. O The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. O (continued) U McGuire Unit 2 B t.6-3 g g,,f L SM
Containment Isolation Valves B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6. 3 d REQUIREMENTS (continued) Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program. I SR 3.6.3.9'h 4 For containment purge valves with resilient seals, I additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, is required to ensure OPERABILITY. The measured leakage rate for containment purge lower compartment and instrument room valves must be s 0.05 L, when pressurized to P,. The measured leakage rate for containment purge upper compartment valves must be s 0.01 L,, 1 when pressurized to P,. Operating experience has O demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment) a Frequency of 184 days was established. I The containment purge upper compartment valves may be used during normal operation, therefore, in addition to the 184 day Frequency, this SR must be perfonned every 92 days after opening the valves. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened. The containment purge lower compartment valves and instrument room valves remain closed during normal operation and this SR is only perfonned every 184 j days for these valves. ' (continued) McGuire Unit 2 B 3.6-26 Svp h M 7---5/2G/07-
Ccntainment Isolation Valves B 3.6.3 l BASES (continued) s l SURVEILLANCE SR 3.6.3/ b REQUIREMENTS , (continued) Automatic containment isolation valves close on a containment isolation signal to prevent leakage of I radioactive material from containment following a DBA. This SR ensures that each automstic containment isolation valve will actuate to its isolation position on a containment ' isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions l that apply during a plant outage and the potential for an unplanned transient if the Surveillance were perfonned with the react,r at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be. acceptable from a reliability j standpoint. ; SR 3.6.3.M This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed
- nanual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J maximum pathway leakage limits are to be quantified in accordance with Appendix J). Penetrations which are not individually testable shall be detennined to have no detectable leakage when tested with soap bubbles while the containment is pressurize The Frequencfyis required by 10 CFR 50, 1 Appendix J, lasmodifiedbyfapprovedexemptions(and y A peM. t are id;&ll kshh I 7pAb% J J t (continued)
McGuire Unit 2 B 3.6-27 gW r_c5/20/07
\
Containment Isolatien Valves
/, , '
B 3.6.3 BASES SURVEILLANCE SR 3.6.3. (continued) REQUIREMENTS therefore, the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J Type test. This SR simply imposes additional acceptance criteria. B .- Bypass leakage is considered part of L,. REFERENCES 1. UFSAR, Section 15.
- 2. 10 CFR 50.36. Technical Specifications, (c)(2)(11).
- 3. UFSAR, Section 6.2.
- 4. Generic Issue B-24.
S. Standard Review Plan 6.2.4. k O , McGuire Unit 2 B 3.6-28 d"ff b*O E/?O/97
$pec.okraddo v'1 3.43 COP'TAIMMENT SYSTEMS O 30**> 57 F P b CONTAINMENT ISOLATION VALVES (IMiTIENf fink FOR/DFFRAT10bH 4C0 3.6.3 1hlc'o"tainment n isciation valve @ shall be ur OPERAp8L uniation useD
, y . _ .. ..1,, ...m.m._.._ . . _ . ,
M APPLICA8ItITY: MODES 1, 2, 3, and 4. '"/D b Al3 MS TIGN: l'd** '%' VS 'O "'Nh ** *- c W L,rdm;p by/d6 ilthoneormore ontainment isolation valve @ inoperable, n ke.ht m., doi .u on vaivr urr r in eacn ,.ii m eo ...o..ii, - t intain h ananatde Leas / g rish"#/hyfee, h
&nsa-T 7Y f estore the inoperable /aive(s) to OPERA 8LE statyt within 4 hou Q, az
$ Isolate sat >Jaffected penetration within 4 hours b use of at least one deactivated automatic valve secured in the iso ation posih Q
(/oco 14 Acneet 4.1 or (c4erp a4c,serAram7 AM6 Isolate O affected penetration within 4 hours by use of at least ytr< vstre sse ~L
,g A' W d'2- one closed manual valve or blind flange, or( j S (wr F L @ Be in at least NOT STANOGY within the next 6 hours and in COLD gg,, p y
SHUTD0tal withia the following 30 hours.
- e. The prov' ions of Specification 3.0.4 a not applicable provided D'#^' O that t affected penetration is isol ed in accordance with ACT b or . above. and provided that th associated system, if app - h !
. tcab , is declared inoperable and appropriate ACTICII stat nts; (Ar to (fo that system are performed. f ,
'# SURVEILtheCE ItE0UIREMENTS O (C4.3.1 tac ^ 6.usainment isolation valve it ce demonstrated vrtesLE pylori to retumin the valve to service after ntenance, repair or replacemenf LA work is w ormed on the valve or its as lated actuator, control or po/er kircuit performance of a cycling tes and verification of isolation Jime. g 54 3.G.3 va Ihal emonstrated OPERABLE diTMiig""Te25t'llT4dt/5 O v-- mr =reor> --->at least prge per 18 eenths by d 44 / cr i l Verifying) hat on a Phase A Contai ecured m h_ [A f,,#S Q g. .6 asolan on test signei Phase A '4 elation valve actuates t its isolation posittee, i {P'5d'*H
- b. Verify that on a Phase B Con inment Isolation test si 1. ea me% w w,n 44 Q l Pha 8 solation valve actua s to its isolation positi , and i p,yg ,,, y
- g. Vey(fyingthatona-r-,1-.e wi-e view.HiaW te sign 4f,ea adu4 /or' 4,, 4 ( pgrye and exhaust valve agtbates to its isolation ittan- $f.,,,.14 /,.g i 54 4.4 The isolation tim,e m to he ,ithin e iimi of each(power
- m. _ _. _on,ratem1B_ , . . automattlvalve
. ~ . . - - -
l
@ a auo< dance ek the.
nScro'<cs 1&si,,4 s%quwe
.i L,29
- McGUIRE - INilT 1 3/4 6-16 Amendment No. 166 O
Pg e l e f tz-
.. ~
.Sj oeC$tatik>t S.(,.3 .
g- ~ - - . f 3/4.6 CONTAffMENT SYSTEMS O* _ 3/4.6.1 PRIMARY CONTAffMENT
, CONTAllMENT INTEGRITY LIMITiffG CONDITION FOR OPERATION
& /T5 3.4./ 3.6.1.1 primary CONTAlletENT INTEGRITY shall be malatained.
APPLICA8ftfTY: #f00CS 1, 2, 3 and 4. *** ' l una - lifthout primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY trithia I bour er be SHlfiDOWI la at trithia theleast NOT followfag 30STAND howrs. 8Y withia the next 6 hours and in COLD d SURVE1LIJWICE REQUfREMENTS jpgff // .6.1.1 primary CONTAlfMENT INTEGRITY shall 6e demonstratedr
.54 3.6 3. (@__ At least once per 31 days by verifyfag that all . penetrations
- act */
Se s.6 3. capable of being closed by OPERA 8tE containment automatic isolattos l valves or operator action during periods den 2eatalament isolation valves are open ander adaimistrative contro1@aCrequired to iI 8 closed durlag accident conditions am closed by valves, blind flanges, or deactivated astamatic valves secured in their posittoas; Thl g contalement at,r lock is la cogitance with c. SecAl#4'kd j After each closing of each penetretion subject to Type 8 testing, except the containment air locks, if opened following a Type A er 8 O 4f IgI'0'j test, by leak rate testtag the seal trith gas at p 14.8 psig, and verifylag that"when the acasured leakage rate for.,hese t seals is added to the leakage rates detersiaed perseant to Specification 4.6.1.2d. for all other Type 8 and C penetrations, the coa 6 feed leakage rate is less than 0.60 L,. hh - l S4 F.6 3 *Except valves, 61 tad flanges, and deactivated automatic E & t, O
$ 4 5 6.E' located inside the contalement and the aansles andiaii' locked, sealed ertv
~
etherwise secured la the closed posittoa. These penetrattoaseshall he J - verified closed daring each COLD SHillDOWI eacept that such verificatica need met be performed more eften than esce per 92 days. '
**The fell valves may t
,. % 4. trati re): IIC-14 en an istdsittent hast[under adat -
- 42, idE-13.)(-23. VX-34, 3r-40, fw11 -13 a ,
***A ene-time change is greated to haw the costalement purge sgply and/or
**amet (seletion valves for the apper and lower ceapartment open in Modes 3 and 4 fellewleg the steas generater replacement estage. The cumulative
'686 hr 175 Mf 3'4. l time for having the valves egea la Modes 3 and 4 is limited to fourteen (14) days. All other provistoms of this specification apply with the excepties of these costatement purge valves apes la Modes 3 and 4. Each we will be sealed closed prior to fattial entry late Mode 2.
MdRIIRE - Ult!T 1 3/4 6-1 '1 -Mt No. {74 56MM O
[- Specification 3.6.3 Insert 12 CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) E.2 ----------NOTE---------- Isolation devices in high radiation areas may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside containment AliQ Prior to entering MODE 4 from MODE 5 if not j performed within I the previous 92 days for isolation devices inside containment SEE SfET E.3 Perfona SR 3.6.3 r Once per 92 days the resilient seal purge j l valves closed to comply / with Required Action E.1. O V McGuire l Page 9 of f L
E
~
CONTAINMDtT t S E @ Sd4A #sA/ VA Lv69 ,
)
dDRVFILLANCEAEOUIRBIDfff)
.54 3.(,. 5. /' ~
N Each containment purge <=riy 'n*'ar *==*"u'IIii}ZEIED valve (s) for _ h the lower compartment and instrument room shall be verified to be sealed F*A closed at least once per 31 days' s A o <j y y __( \WWl a'n ,pe*nt.h kuin
.6. .2 The c tive time tha 11.contain purge su y and/or t Av p.4A WI l'a t i
. x st isolat Ives for th per compart t.h~ ave b open during 9 l
.adar wear 11 be detecai at least ner 7 ..
$Ga4g. C eg H) s .
{ s1 s s x cr7Fr>y @At { east once per&r6 no thsCgsf1 ST6GGOtED TESPBAji3NEach-strJa1e j containment purge wwor *==="wisoisuon snive surnlower
) e rtment and instrument room with resilient material seals (sna pir_e cepmra
\ y verunny snat tne measuren eramaue rate is sc3> to w a sri eg surizeVto 9,fg 4,_ g4 4p4 a vi d At Ilast' once per 3.monthsC c ainment p ' 43NiUPEil7B- I unmini hau . f.6 iarr iT4 unoer compartment we res llent material l seals lsh/1 be 4etongtrited QPERABLTky veniy y at tne mes mrru ir--
fits is less saan o.va L, wherAressurized to . - p.4% ym m rg (, mA
~
McGUIRE - UNIT 1 3/4 6-14 Amendment No. 166 O e to sf /2-1 j
Specification 3.6.3 O INSERT SR 3.6.3.2 Verify each containment purge and exhaust 31 days isolation valve for the upper compartment is closed, except when the valves' are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. O McGuire 1 Page10stof lZ
- 1 l
r CpeifichltS- ?. loa.3 -
, CONTAlletENT SYSTEMS CONTAlletENT traaradr O
l LIMITinC CO E TTION FOR OPERATION I 3.6.1.2 Containment leakage rates shall be limited to: see ##//( a. of /75 3.y/ 6, An overo11 integrated leakage rate of less than er equal to L ,
, N,hweight of the containment air per 24 hours at P,,
\b. A combined leakage rate of less than 0.60 L for all penetrations l
N_sand and valves subject to Typa 8 and C tests, ween prassurized !
/ACgd/ ##
- c. A bypass leaka tio rate of less tha .07 L for aIpenetra-SR 't dr< identified as s ary containeen ssurized to P . ypassl,akagpathswhen e .l APPLICABILITY: MODES 1, 2, 3, and 4.*
- y. See/TS khrk
- gppj l eG B.4 y/
\ Of M 9.4/ \
With (a) - l L, or (b) the measured combined leakage rate for and ations all penmea... A- ) ves sub.iect to Tynes B and C tests exceedino 0.60 t . or
~
/" ypass Tes e rate exceedtigi-.w g the comoined ir.i. i ... E=.6.is i., .no so. .;d restore thef.... .ii integrates leakage
#mit -in land va1 wee muMeet tah8 and C tests to- less combined bypass leakane rate ap .... - - r v.W
- andt van theseanspe 0.60 rate for all penetration Gear,sor coolant spGs tv,Mture aged 200'F nor se / Asi.pthe gjg O SWtVf1LLANCE REOUIREMENTS \pinan /sieestt3 in Y ADWPS Sec h (af f4.6.1.2 Type A containment leakage rates shall be demonstrated as 10 CFR 50.54(o) and Appendix J of 10 CFR 50, gg,g,j e , tion 8, as modified by approved
' in accordance with the guidel nos of Regulatory Gui
~
see-time change is granted to have the containment purge supply and/or
<gg py/ exhaust isolation valves for the upper and lower compartment open in Modes 1 3
~
forand 4 following the steam generator replacement outage. The cumulative time of / TS 3. ,/ havi t h valves open in Modes 3 and 4 is limited to fourteen days. A 14) other provisions of this specification apply with the exc(eption of those containment rurge valves open in Modes 3 and 4. . Qclosed prior to initial entry into Mode 2. Eachvalvewillbe) McGUIRE - UNIT 1 3/4 6-2 Amendeert No.174 8 llDb & O
Q C d a.:a f e;. S.6 3 CONTAINMENT SYSTEMS 'O t D) SURVEfttANCE REOUTREMENTS (Continued) Y dI#h
.&i- MS 5.M the test medium.
interval are not changed by this exception.The above require e. Purie supply and exhaust isolation valves with restilent materlat seals shall f Kneef be tested flemtion and 4.6.1.g3 deennstrated OPERABLE by the require or 4.6.1.9.d at ann 14enhia* f 4 3./.3, (ypify)he
- f. A T combineddggisllpQWfuenor hushy Bypas laa.*Me eakage rateAnatrysderersrfhe j3, pHs) l ec.07 LggTIFc4:ne Type's anyr c te,sTs atAcast pace per ess z n g,34 (hxneppenetrationsnotindividrexcept for penetrations which are 43p no
/ -
ually testable shall be dete ngd to hav y acot//Merdh no detectable leakage when tested with so_ap !>ubbles T.ainment is pressurized to P.,14.8 psig ile the con-GE3irTach-Tyne-K
/f 8 (g.
Air locks shall4.6.1.3; be tested and demonstrated OPERABt.E per l g i Specification . $TET -
.e e/ap/d*5
- h. gp The space between each dual-ply bellows assembly on containment Sge \ be vented to the annutus during Type A tests. penetrations of each Type A test M M E'0' assembly shall be su,bjected to a low sig pressure to tes be subjected to a leak test with the pr6ssure on t side of the dual-ply bellows assembly at P.,14.8 psig to verify l the 1eakage to be within the limits of Specification 4.6.1.2f.; J O. i.
All test leakage rates stia11 be calculated using observed data
. converted to absolute values.
elect a balanced Integrated Leakage Measurement Systent a gee sf \ h feportstgof Sppc1tif.atiotD 0.2 j not applicable. N'tfMU$) 0 f)pft. McGIIRE - UNIT 1 3/4 6-4 Amendment No.173 ge /h b h &
$pe e de erkto r1 5.6*.S CONTAllplENT SYSTEMS (NGT) CONTAINNENT ISOLATION VALVES
'O'*5.4.J 61NIMME tantTIM FOR OPERATJdD l tco 3.6.3 @tainment isolation N1 vee shall be OPERA 8tifwith isolatio Vtimes) a-- ,-_..-.n.__., - Q& APPLICASILITY: IWDES 1, 2, 3, and 4. eYeeft W&ryc nlVV. 4 4 e , j.a,,- (INSdt-14 tT***6'Ab*** A* A'Shb) "' #"b "'I ** Afl* H f
'l ith one or morefcontainment isolation valve @ inoperable fiaintaTn atfeast #"*"Y
@#De isolation vaswr w----i in -
suecten __irnoon that is anaa And 4 4,,y (a. tore the inoperable v4Tve(s) to cruuuu szatus within e m.mg f Isolate effected penetration within 4 hours by use of at least Aalan A.l i()^one deactivated automatic valve secured in the isolation positian- ea or cGe ,M dk 4 ;, k Isolate ffected penetration withip 4 hours by use of at least}' one closed manual valve or blind flange, vf l A"'#d d. Se in at least HOT stale 8Y within the next 6 hours and in COLD M.3 Artised 41 E SHilTD0lNI within the following 30 hours.
" b## I . The isions of Specifica on 3.0.4 are not app cable provisec ~
y,,y p -that affected penetra on is isolated in acc with ACTI
- b. o c. above, and prov that the associa system, if app -
#"N i cab , is declared i aale and the anstmo l
te ACTION stat '___ts) g7,,a g o that system are ormed. f NW '8/ SamvEILLANcE afnufREMENTS l,0. 4.6.3.1 - containment isolation valve 11 be demonstrated OPERA 8t.E o to return valve to service after ma ace, repair or replac 44.5 luork is ormed on the valve or its as lated actuator, control or r .it (circuit serformance af a evcifog test verifica+1am of isolatio ime 54t 6.L - val trated OPERA 8tE / *
----- or -u=> -~ at least once per 18 months ( @ j'Q' Mj" Il
~
A. Verifying on a Phase A Contal avieiian test signal, CR M' ' I Phase A iso ation valve actuates to isolation position,
- b. Verifylm t on a Phase 8 Contal t Isolation test signa each l
$a han g,j Phase 8 lation valve actuates its isolation position, ad
{
- I
- c. Verifyi/s.that onhtainment Wiggy-Hid test si 1, eac esitdn en N suree And exhaust valve actuate ( to < ts - so ation sos _iti an edu l 54 5.c.5.hrI 12h The isolation time of.each cover oseratasap automatickvalve CEK1 Tan a
@ er 5:e ke
- == ;- r --e 'a 7""-% n a sN! l V to be within@ .Lw.
(D ifei+ @ w ihe Dserees9 'Glc y Y'T* McGUIRE - 1st!T 2 3/4 6-16 Amendment No. 148 i O ; 8p lof G-1
s;us w.on s.&.5
~
3/a 6 c0NTAfWD(T STSTEMS O,
- 3/4.6.1 PRIMARY CONTAlmENT ,
CONTAfMENT INTEGRffY See Nad'yp UNITING CMDIN N OPERAN N
- d / T5 3.f./ 3.6.1.1 Primary CONTAIMDIT INTEGRITY shall be saintained.
APPLICARILITY: MODES 1, 2. 3. and 4. ^** ACIEE. lifthout primary CONTAlleID(T INTaiRITY. restore CONTA!MD(T INTEGdITT 1 hour or SWTDOW bethelafollowfag within at least NOT 30 hours. STAND 8Y with{a the next 6 hours
~
SURVEfttANCE REOUfREMDf13 k4.6.1.1 LP e Primary CONTAlfeID(T INTDIRITY shall be demonstrated: [ fgsgff // '@ At least once per 31 days by verifying that all penetrations
- not C# 3'6 3. 3 valves or operator action during periods whenaonta 54 s.G.B.M valves am open vader adatatstrative contro15tgand required to be closed during accident conditions are closed by vaives, oliod- g r flanges, or deactivated automatic valves secured in their posittoast
( b'.Specificatfoe By verifylag that eachand 3.6.1.3; costalament air lock is la compliance with
- c. After each closing of each
,3 ,e p ,j, p \ tratfeasutJect to Type 8 testing,
" except the contalaant sir focks if opened followles a Type A or 8 Y \ 14.8 psig,at and g jg 3,4,f test, bythat verifying leak rate testingleakagethe seal with gas is P ,h O added 4
h.6.1.2d. kage ratefor the measured allthan is less other 0.60Type L,. rate for t ese to the leaka e rates determined pursuant to $peelfication seals 8 and C penetrations, the com Y O* 0'3'N *Except valves, b1 fad flanges, and deactivat M N he ENA located lastde the containment and the annulus g 3,g,3* otherwise secured in the closed posittoa.* These art atomaticvalveswhichare locked sealed penetrattoas,e s hallorbesteauce, verifted closed during each COLD SWT00W erscept that such vertftcationf- l need not be performed more often than es.ce per 92 days. (..M **The
, trativefollowing controlavalves may be openee on as lateruittent basis mader admints.
f l NC-141. NC-142, idE-13. IIE-23, VK-34. VK-40, Ell, 513 I pc g w ***A one-ttee change is granted to have the contataseat po 7 3 and 4 following the steam generator replacement outage. b j/5 "4* / time for having the valves opea la Modes 3 and 4 is limited to fourteenThe cumulative (14)d*TS- AiI 'th'r F i5i'*5 'i **i' 5 Ci "**t (r.l#n Apply with the exceptime of those containment purge valveopea s Modes 3 and 4. Each ) valve will be sealed closed prior to initial entry fato Mode 2.
/
McGUIRE - W IT 2 3/4 6-1 Amendment No.156 Q foy [ *[ f
[ Specification 3.6. 3 Insert 12 CONDITION REQUIRED ACTION COMFLETION TIME l l l E. (continued) E.2 ----------NOTE---------- Isolation devices in high radiation areas may be , verified by use of administrative means. Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside containment M Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 (b
)
days for isolation devices inside containment sitT E.3 Perfonn SR 3.6. for Once per 92 days ) the resilient seal purge / k valves closed to comply with Required Action'E.1. McGuire Page 7 of /2_
S)L'&tScs./cw h 3.6 3 CONTAlletENT hu n) vALj ISUB(ElllAICEdtEDUfREMENfD
$4 '5.6.3./
A7F"T3R'h Each containment purge ^=1rm?-r
@ -- - -r senimttaa valve (s) fot L,g the lower compartment and instrument room shall be verified to be sealed
.axep{.Q, ' sat PM closed at 13ast once per 31 daysf vtalvt. f a a putie __
c - (tw f.S d'du'r. 4%I The .-~ -lative t that containeen purge s y or d 15d[IJEffp valv ( c the compa e.Jth e .t. Sis e a-r .= 11 u .mfa t least- we
~ ring . lI s
O'
~
WIMstitT
' ~
\
g,yh
.n. Nb s.t,,3,yg renhcontainment purge 6 At least
_ .y wram ,""" x-_TE$T once-p pethrqFnA .m 8"__.phiffenerve.miaa
... % lower 56 te.k , co eso - ^ w instrument noe with resilient materia sesturedAtawratetspss-tegns uruk *Nm 4- (trater1MEMI.Et EM u ---- =~ g' rif Q . g 3,4, 5. h e x i x ,
(peek ww m u+,.s q
- giiiiiiiii'lE7D
; ti sr least latiofvalve _oncer per 3 monthsYMcontat.D.P, Nonpartmentd res rI51ent art g seals 1 be g s ted (irtTylneAhat tne momenceuse --m rare is ====
r=== u.UI L ...... p a s rea to P,JC )
%cG e
L O O e e McGUIRE - talIT 2 3/4 6-14 Amendment No. 148 i O -
. saaa
1 Specification 3.6. 3 O INssRT SR 3.6.3.2 Verify each containment purge and exhaust 31 days isolation volve for the upper compartment is closed, except when the valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for SurvetIlances that iequire the valves to be open. !O McGuire 1. Page10% of l 2.
Sper[bt[/Ok GrNnrNT sysTEns 30,3 CONTAINMENT LEAKAGE ' LIMITING riunfTION FOR OPERATION 4.6.1.2 Containment leakage rates shall be limited to: dM a.
@f c /T5 3/ An overall integrated leakage rate of less than or equal to L;,
0.305 by weight of the containment air per 24 hours at P , 14.8 psig, b' . A combined leakage rate of less than 0.60 L for all penetrations and valves subject to Type 8 and C tests, w$en pressurized and ; to P.,
/hu /A I A combined bypass leakage rate of less than 0.07 L for a 1g3,(,, g, tionsidentifiedassecondarycontainmentbypassleakagepathswhe ressurized to p,. ,
{ APPtICABILfTY: MODES 1, 2, 3, and 4.*
/feeAvt*/#' ACTION: l
\ /1'S 5.G 1 _
/$fMD y rate W d*M Witf(a)
.5L or (b the measured overall integrated containment leakage alves,subjec)t to Troes B and c teett erraadina o.so tthe measured ( c
>A,3)9 QAlell/hvi...
- ;ge.v. rese wasvecingMDdCD ~ o the comblned -
WM <rhe w sess than 0 n L, anicwe w ,, restore
. the verali integrated leakage inea senta
# #5 # and valves suMeet to Troe 8 and C tette ta 1===ge +k= rate for all penetratio 0.60 L . and the combined bypass leakage rateft'o1 than O. L
{Mje etor upiant syy teprat above 'F. . p toJKereaping e SURVEfLLANCE REQUIREMENTS # #5 O 'pg Afgp A f4.[i.2 Type A containment leakage rates shall be demonstrated as required b l T P 10 CFR 50.54 o) and Appendix J of 10 CFR 50, Option B, as modified by apj of17534.// exemptions, September, 1995. a(nd in accordance with the guideline d I 1
- l l
[ l See MUM'* # cf. j75 y,/g,/ *A one-time change is granted to a have the containme't 3 p 3 and 4 following the steam generator replacement outage. The cumulative time I for having days. the valves open in Modes 3 and 4.is liettec. to fourteen (14) ! All other provisions of this specification apply with the exception of those containment purge valves open in Modes 3 and 4. aled closed prior te initial entry into Mode 2. Each valve will be j , 1
-_ f !
McGUIRE - UNIT 2 3/4 6-2 Amendment No. 156 l l l l I
,a y //o/ m
1 Speci M .k s.&. 3 CbMTAINMENT SYSTENS l SURVEILLANCE REOUIREMENTS (Continued 1 Sed N#4 the test medium.
' interval are not changed by this exception.The above requimd
- e. pu es sealssha and exhaust isolation valves with restitent material ,
specification a K 1 o 1 ae C8_J.9 a me t maalicable-be J I tes St S./s.3, e coe6fned Tirwv-savakr 5;iss mmD N .07 le*maa rate dhalT De1eWIAetF ess than '
'cabit TaniB ms8 C tests av eastecemr znatte7 pi /ccs/em'd.MN xcept~for penetrations which art. net individually testable; oegg pdr7ln ~ h #rle netrations not individually testable shall be det detectable leakage when te<ted with sa=a 'ned to ha W
.38
,g tainment is pressurized to P ,14.8 psig(ug
=-tele F tne c i er.n i iey C W as 4d .
[ Air locks shall Specification 4.6.1.3;be tested and demonstrated OPERABLE T~
- h. ilfaqw g Thespacebetweeneachdual-plybelkowsassemblyoncontainment netrations between the containment building and the annulus shall vented to the annulus during Type A tests. Followl of each i
/ fed Afv/( assembly A test, 11 the spacetobetween be subjected a low each dual-ply be lowscompletion veri no detectable leakage or the ressure test at 3-5 g to be s al-ply bellows ass -shall
( ef /73 3 4./ side ofjected to a leak test with the pressure on the containment the dual ly bellows assembly at 14.8 psig to verify the 1eakage to be wi in the limits of Speciff tion 4.6.1.2f.; - l 'O i All test leakage rates shall be calculated using observed data converted to a6 solute values. MI t select a balanced Integrated Leakage Measurement System; a [ Q e M vlsi n(3 of S ftfeifi3ati 0.2 4EP not appitcable. *
~* ' ~
McGUIRE - UNIT 2 3/4 6-4 Amendment No.155 O gaa
B Discussicn of Chingss l S2ctien S.6 - C:ntainment Systems j ADMINISTRATIVE CHANGES These changes, retained in ITS SR 3.6.3.76, 3.6.6.3, 3.6.3.3 and - 3.6.36.4, are consistent with NUREG-1431. A.19 CTS LCOs 3.6.3 and 3.6.1.9 are being combined into ITS LC0 3.6.3," Containment Isolation Valves". The two CTS LCOs duplicate the requirements for the valves used for containment penetration flow path isolation. Since the wording of CTS LC0 3.6.1.9 is repeated in the Action, it is eliminated. Minor wording modifications are 1 made in combining the LCOs, but these changes do not alter the technical requirements. This change is considered administrative and is consistent with NUREG-1431. A.20 Not used. CTS 3.5.1.0 ^.ction : require; inoperable valve; bc rc;tered t OPER^3LE :tatu; within 2'! hour;. ITS 3.5.3 .^. tion E require; th: ;; valve; to be i;clated by u;c cf at le :t one cle;;d nd de ::tivated automatic valve, cic;cd : nual valve, or blind flange. I;;lating a containment penetration valve en;ure; the valve i; perf0:-ing it; ::fety function and i; On :ppropriate
- pen; tory ::ti:n. Thi; ch:ng i; n;idered an dmini;trativ
, ch:nge :nd i; con;i; tent with TJREC l31r A.21 Not used.
A.22 CTS 4.6.2.c.3 and 4.6.5.6.2 require that system functions in response to the Containment Pressure Control System (CPCS) be e verified. CTS 4.6.5.* .f refers to a required start permissive signal for hydrogen skimers but does not state the source. ITS i 3.6.6, 3.6.8, and 3.6.11 surveillance requirements provide the specific requirements to be verified and refer to the start permissive and terminate signals of the CPCS. The setpoints are already specified in CTS 3.3.2 and retained in ITS 3.3.2. This change does not alter any surveillance requirements and is therefore considered an administrative change. A.23 Not used. A.24 C15 LC0 3.6.1.8 Action b allows the ventilation system heaters to be inoperable up to 7 days and allows continued operation of the system provided a report is made to the NRC within 30 days. The report is required to state the reason for the inoperability and the planned actions to return the heaters to operable status. This allowance is reformatted ar.d retained as ITS 3.6.10 Action B. McGuire Units 1 and 2 Page A - 67 Supplement 25/20/07l
Discussicn of Ch:ngIs Siction 3.6 - C:ntainment Systems 3 [V ADMINISTRATIVE CHANGES entering CTS LC0 3.0.3, this change is considered administrative. This change is consistent with NUREG-1431. A.33 Not used. A.34 The requirements in CTS 4.6.1.2.f for bypass leakage testing on a 24 month basis during applicable types B and C testing has been revised. The frequency in ITS SR 3.6.3.67 is in accordance with l 10 CFR 50 Appendix J, as modified by approved exemptions. The proposed change is considered administrative since 10 CFR 50 Appendix J establishes a maximum interval of 24 months for types B and C testing, therefore, the existing requirement is maintained. This change is consistent with NUREG-1431. A.35 CTS 3.6.1.7 requires the structural integrity of the reactor building be determined during the shutdown for each Type A containment leakage rate test or if the Type A test is performed at 10 year intervals, two additional inspections shall be performed at approximately equal intervals during shutdowns o between Type A tests. Since the station performs Type A tests d every 10 years the frequency of 40 months was established since it is equivalent to one inspection performed every 10 years and two other inspections performed at equal intervals within that 10 years. This change, retained in ITS SR 3.6.16.32, is considered l administrative since it does not change the present intervals for inspection. A.36 Not Used. A.37 CTS 4.6.4.3.a requires that 32 of 33 hydrogen igniters be operable on each train. ITS SR 3.6.9.1 requires 34 igniters per train to be operable. The actual design contains 35 igniters per train. This change simply corrects an inadvertent error in the CTS. The number of igniters was increased as discussed in SER Supplement 7, Attachment C, after the first refueling oatage of each unit. This change corrects the TS with the approved licensing basis as described in the SER supplement. A.38 CTS 3.6.1.2.c and 4.6.1.2.f specifies requirements for reactor building bypass leakage limits. These requirements and associated
,3 actions and surveillance requirements are combined with the
)-
/
McGuire Units 1 and 2 Page A - 97 Supplement 25/20/07l
i Discussirn cf Ching::s Section 3.6 - Contninment Systems q TECHNICAL CHANGES - LESS RESTRICTIVE (nd' the interlock function is required. The door interlock mechanism cannot be readily bypassed, linkages must be removed, which are under the control of station processes such as temporary modifications, containment closure procedures, and out of services practices. Failure rate of this physical device is very low based on the design of the interlock. Historically, thi interlock verification h:: had it; frequency chc;cn te coincide with the frequency of the ever:11 cirlock leakage te;t. tccrding tc 10 CFil 50 Appendix J. Option A, thi; frequency is once per 5 months. McwcVer, Appendix J Option S, allcw; for an extensica of the overall air lock leakage te;t
# equency to a maxi = cf 30 month .
For the above reasons, it is proposed to change the required frequency for this surveillance to 18 months. In this fashion, the interlock can be tested in a MODE where the interlock is not required. This change, retained as ITS SR 3.6.2.2, is less restrictive and consistent with Technical Specification Task Force (TSTF)-17 approved change to NUREG-1431, except a shorter 18 month f) \J frequency is proposed consistent with the refueling cycle. i' L.7 CTS 3.6.3 Action c is revised to add an additional method of isolating an affected penetration by allowing the use of a check valve inside containment with flow through the valve secured. This is an acceptable isolation method and does not impact the health and safety of the public. Providing an alternative method of isolating an inoperable containment isolation valve is considered less restrictive. This change, retained in ITS 3.6.3 , Action A.1, is consistent with NUREG-1431. L.8 CTS 4.6.1.1.a and an associated footnote requires verifying the manual valves and blind flanges inside and outside the containment are closed. ITS SR 3.6.3.33 and 3.6.3.43 contain a note which l permits valves and blind flanges located in high radiation areas to be verified by administrative means. A similar note is also added to the CTS 3.6.3 and 3.6.1.9 actions to provide the same flexibility for valves required to be verified closed as a result of required actions. This is considered acceptable, since access to high radiation areas is restricted for ALARA reasons. The O probability of misalignment of these devices, once they have been G/ initially verified in the proper position, is small. The term McGuire Units 1 and 2 Page L - 33 Supplement 25/20/07l
Discussi n cf Changes ] Srctirn 3.6 - C:ntcinment Systems TECHNICAL CHANGES - LESS RESTRICTIVE
" isolation devices" is inserted for, " Valves and blind flanges" ;
and retained in ITS 3.6.3 Action A.2, C.2, and E.2 Notes. This change modifies the existing technical requirements and is considered less restrictive. The change is consistent with NUREG-1431. L.9 The time limitations applied to opening the containment purge valves in CTS 3.6.1.9.b and 4.6.1.9.2 are deleted from the TS. Limitations on the time the valves can remain open are based on the cumulative releases permitted by the radiological effluent . monitoring program. The radiological effluent controls are described in ITS 5.5 and implement the requirements of 10 CFR 20. These requirements provide assurance that the doses to members of the public are controlled within specific limits. Therefore, the application of a predetermined time limit within the TS is not warranted. ITS SR 3.6.3.2 requires the valves be verified closed except for the reasons allowed in the CTS. Thus, use of the system will continue to be minimized and limited to specific reasons. In addition, these valves are fully qualified to close p in the required time upon receipt of a containment isolation signal. The change is consistent with NUREG-1431. L.10 CTS 3.6.1.2 Action requires the combined bypass leakage rate to be within limits prior to increasing the Reactor Coolant System temperature above 200 *F. CTS 3.0.3 would be enteredN: ::ti er,; cre :p :ified if the unit is discovered outside the limits in , MODES 1, 2, 3, or 4. ITS 3.6.3 Action D requires the combined 1 bypass leakage rate limits to be restored within 4 hours in MODES l 1, 2, 3, or 4. Allowing 4 hours to correct any bypass leakage limit problem provides an alternative to placing the plant in a l shutdown evolution unnecessarily. This is acceptable because of l the low probsbility of an accident occurring within this time period that could cause a radioactive release through the bypass leakage path. The change is consistent with NUREG-1431. ; L.11 A Note is added to CTS 3.6.4.2 Action to provide an exception to Specification 3.0.4 that would allow Mode changes to be made with one inoperable recombiner. The Note is appropriate since the other hydrogen recombiner remains available to perform the post accident function and since the hydrogen recombiners in no way affect p nonnal unit operation in MODES 1 and 2. This change, retained in ITS 3.6.7, is consistent with NUREG-1431. McGuire Units 1 and 2 Page L - 45 Supplement 25/20/97l
Discusstn cf Ch:ng:s Secttn 3.6 - C:ntninment Systems I TECHNICAL CHANGES - LESS RESTRICTIVE V L.23 Not used. L.24 CTS 3.6.3 requires isolating penetrations with inoperable containment isolation valves within 4 hours. General Design Criterion (GDC) 57 allows the use of a closed system in combination with a containment isolation valve to provide two containment barriers against the release of radioactive material foll wing an accident. CTS 3.6.3 does not allow the use of a closed s tem to isolate a failed containment isolation valve. A closed system typically has flow through the system during normal operation such that any loss of integrity could be continually observed through leakage detection systems within containment and system walkdowns for closed systems outside containment. As such, the use of a closed system is equivalent to isolating a failed containment isolation valve by use of a single valve. ITS LC0 3.6.3 provides 72 hours to isolate an inoperable isolation valve associated with a closed system. The 72 hours provides the necessary time to perfonn repairs on a failed containment isolation valve while relying on an intact closed system. The 72 m hour completion time is appropriate given that certain valves may be located inside containment, the reliability of the closed V system, and that 72 hours is typically provided for losing one { train of redundancy throughout the TS. The change is consistent ( with generic change TSTF-30 to NUREG-1431. { L.25 CTS 4.6.1.9.3 requires testing the containment lower compartment and instrument room purge valves with resilient seals 6 months on a staggered test basis. ITS SR 3.6.3.65 does not require the l l testing to be staggered but maintains the 6 month (184 day) i surveillance frequency. The test connections for the purge valves are located between the valves in the penetration, therefore, both { valves are leak tested simultaneously whenever testing is ' performed. The requirement to perform staggered testing, therefore, cannot be implemented on an inbeard/ outboard valve basis. Deletion of the requirement to perform staggered testing is acceptable since the valves within the penetration cannot be , tested separately, the valves remain closed during MODES 1-4, and )' the valves have been shown to pass the surveillance on a 6 month frequency. Additionally, the surveillance interval for the containment upper compartment purge valves is extended to 6 months ! q from 92 days for valves that have not been opened. Increased ) b McGuire Units 1 and 2 Page L - 810 Supplement 25/20/97l , l I
Discussicn cf Ch:ngss i Section 3.6 - C:ntainment Systems TECHNICAL CHANGES - LESS RESTRICTIVE L.27 CTS 3.6.4.3 does not include an Action for the Condition where there is no OPERABLE hydrogen igniter in one containment region. ITS 3.6.9 adds this new condition and requires a hydrogen igniter be restored in the affected containment region to OPERABLE status within 7 days or be in MODE 3 witP n 6 hours. This change provides actions consistent with a footnote to CTS Surveillance 4.6.4.3.a which requires that inoperable igniters not be on redundant circuits in the same region. CTS 3.0.3 would be required to be entered if this condition existed in the CTS. This change is acceptable because of the low probability of an event occurring within the 7 day completion time that would generate an amount of hydrogen that exceeds the flammability limit and the availability of the hydrogen recombiners, hydrogen skimmers, and hydrogen monitors. This change is consistent with NUREG-1431. L.28 CTS 4.6.3.2, 4.6.2.c, 4.6.5.6.1.a 4.6.5.6.1.d, and 4.6.1.8.d.2 require that the specified testing be performed using a " test" signal. ITS SRs 3.6.3.76, 3.6.6.3, 3.6.6.4, 3.6.8.4, 3.6.10.3, l 3.6.11.1 and 3.6.11.3 permit the use of an actual or simulated n actuation signal for testing purposes. This change permits credit () to be taken for unplanned events (actual signals) which provida the necessary data to satisfy the SRs. The actual signal is what is credited within the safety analysis and is sufficient for demonstrating compliance with the SRs. This change is consistent with NUREG-1431. L.29 CTS 4.6.5.3.1.a requires continuously monitoring inlet door pasitions. ITS SR 3.6.13.1 requires the door position be monitored every 12 hours. Continuous monitoring of inlet door positton is accomplished by the Inlet Door Positton Monttoring System, CTS 3.6.5.4. This specification, however, is relocated from the TS as discussed in R.2. The requirement of 12 hours is a less restrictive change. The proposed change is acceptable since the 12 hours is consistent with the monitoring of ice bed temperature which is the parameter of concern with an open door. L.30 CTS 4.6.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room are scaled closed. ITS SR 3.6.3.1 verifies that these volves are sealed closed but provides an exception to open one purge valve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs. The exception was added to establish the allowance of opening a McGuire Units 1 and 2 Page L - 10M Supplement 25/20/97l
l Discussicn cf Chang:is Section 3.6 - Containment Systems , (~N 1 ( ) TECHNICAL CHANGES - RENOVAL OF DETAILS s LA.23 CTS 4.6.3.2 requires performance of containment isolation valve j testing during cold shutdown or refueling. This detail is not j required within the TS to demonstrate operability and is relocated to the BASES for ITS SR 3.6.3.76. The Bases are subject to the l controls described in Chapter 5 " Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.24 CTS 4.6.2.b requires the containment spray pump meet a specified value when tested pursuant to Specification 4.0.5. ITS SR 3.6.6.2 requires that the pumps develop the required head pressure required by the Inservice Testing Program. Relocation of the required pressure to the Inservice Testing Program is acceptable since this program must meet the requirements of 10 CFR 50.55a. Changes to the procedures which implement these requirements are controlled by the procedure change program. These controls ensure that changes are appropriately reviewed and conform to 10 CFR 50.55a requirements. These changes do not change any technical O d requirements or change the present way of performing these surveillances and are therefore considered administrative. These changes are consistent with NUREG-1431. LA.25 CTS 1.7 items a, b, c, and e define the attributes of containment operability and integrity. These attributes have been relocated to the Bases for ITS 3.6.1. The descriptive attributes are more appropriate information for Bases and are not necessary to be included within the Technical Specification. The requirement to maintain on operable containment is retained in ITS 3.6.1. The Bases are subject to the controls described in Chapter 5
" Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431.
LA.26 Descriptive informatton regarding the containment personnel access doors and hatches in CTS 3.6.5.5 and the divider barrier scal in CTS 3.6.5.9 is moved to the Bases for ITS 3.6.14. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more ( oppropriate for the Bases. The Bases are subject to the controls C McGuire Units 1 and 2 Page LA - 7 Supplement 25/20/97l
N3 Signific nt H:zirds C nsider!.ti:n Sectica 3.6 - C:nt inment Systems j%
;v) LESS RESTRICTIVE CHANGE L.8 The McGuire Nuclear Station is converting to the Improved Technical l Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive.
calow is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.1.a and an associated footnote requires verifying the manual valves and blind flanges inside and outside the containment are closed. ITS SR 3.6.3.33 and 3.6.3.43 l contain a note which permits valves and blind flanges located in high radiation areas to be verified by administrative means. A similar note is also added to the I CTS 3.6.3 and 3.6.1.9 actions to provide the same I flexibility for valves required to be verified closed as a result of required actions. This is considered acceptable, since access to high radiation areas is restricted for ALARA reasons. The probability of misalignment of these devices, ) once they have been initially verified in the proper Q position, is small. The term " isolation devices" is V inserted for, " Valves and blind flanges" and retained in !TJ 3.6.3 Action A.2, C.2, and E.2 Notes. This change modifies the existing technical requirements and is considered less restrictive. The change is consistent with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications I change and detennined it does not represent a significent hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated? l The proposed change does not result in any hardware change. The isolation devices are not assumed to be an initiator of any analyzed event. The isolation devices are passive and serve to limit the consequences of accidents. The proposed change ensures the isolation devices remain positioned to limit the consequences of design basis events as described in the UFSAR. Additionally, the proposed change does not alter the plants ability to detect
,m - and mitigate an accident previously evaluated. Therefore, this
() change does not involve a significant increase in the probability i McGuire Units 1 and 2 Page 2063 of 6968 Supplement 25/20/97l L_________ _ _ ___ _
)
No Signific nt H;z rds C:nsideraticn Secticn 3.6 - Containment Systems n \ (G LESS RESTRICTIVE CHANGE L.9 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. The time limitations applied to opening the containment , purge valves in CTS 3.6.1.9.b and 4.6.1.9.2 are deleted from the TS. Limitations on the time the valves can remain open are based on the cumulative releases permitted by the radiological effluent monitoring program. The radiological effluent controls are described in ITS 5.5 and implement the requirements of 10 CFR 20. These requirements provide assurance that the doses to members of the public are controlled within specific limits. Therefore, the application of a predetermined time limit within the TS is not warranted. ITS SR 3.6.3.2 requires the valves be verified closed except for the reasons allowed in the CTS. O Thus, use of the system will continue to be minimized and V limited to specific reasons. In addition, these valves are fully qualified to close in the required time upon receipt of a containment isolation signal. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The containment upper compartment purge valves'are not assumed to be the initiator of any analyzed event. These valves are required to be capable of closing upon a containment isolation signal. This change does not alter this assumption relative to an accident or transient event. Thus, the consequences of an accident are not affected by this change. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. () V l McGuire Units 1 and 2 Page 229 of 6968 Supplement 26/20/97l l l J
No Sigxificcnt X:zerds C:nsid:raticn L S:cti:n 3.6 - Cntninment Systems LESS RESTRICTIVE CHANGE L.25 The Catawba Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change'and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.9.3 requires testing the containment lower compartment and instrument room purge valves with resilient seals 6 months on a staggered test basis. ITS SR 3.6.3.66 does not require the l testing to be staggered but maintains the 6 month (184 day) surveillance frequency. The test connections for the purge valves are located between the valves in the penetration, therefore, both valves are leak tested simultaneously whenever testing is performed. The requirement to perform staggered testing, therefore,cannotbeimplementedonaninboard/outboardvalve basis. Deletion of the requirement to perform staggered testing is acceptable since the valves within the penetration cannot be tested separately, the valves remain closed during MODES 1-4, and the valves have been shown to pass the surveillance on a 6 month x frequency. Additionally, the surveillance interval for the containment upper compartment purge valves is extended to 6 months from 92 days for valves that have not been opened. Increased surveillance intervals were established for valves with resilient seals which were opened during operation. This change is acceptable since it maintains the increased interval for valves that are actually opened. This change is consistent with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the Catawba Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
These valves are not assumed to be the initiator of any analyzed event. These valves are required to be capable of closing upon a containment isolation signal and most of the subject valves are n required to remain closed during normal operation. This change C). does not alter this assumption relative to an accident or McGuire Units 1 and 2 Page 5063 of 6968 Supplement 25/20/97l , l
i N3 Sig2ific nt E:zcrds C:nsidirstica Secticn 3.6 - C:r.tainment Systems LESS RESTRICTIVE CHANGE L.28
- d .
The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.3.2, 4.6.2.c, 4.6.5.6.1.a. 4.6.5.6.1.d, and 4.6.1.8.d.2 require that the specified testing be performed using a " test" signal. ITS SRs 3.6.3.76, 3.6.6.3, 3.6.6.4, 3.6.8.4, 3.6.10.3, l 3.6.11.1 and 3.6.11.3 permit the use of an actual or simulated actuation signal for testing purposes. This change permits credit to be taken for unplanned events (actual signals) which provide the necessary data to satisfy the SRs. The actual signal is what is credited within the safety analysis and is sufficient for demonstrating compliance with the SRs. This change is consistent l with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire
/' Nuclear Station has evaluated this proposed Technical Specifications V] change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
l
- 1. Does the change involve a significant increase in the probability l or consequence of an accident previously evaluated?
The proposed changes permits the use of unplanned events in addition to simulated signals to be credited in the performance of surveillance requirements. The initiation signals associated with testing are not considered initiators of any analyzed event. Therefore, the probability of an accident previously evaluated is not significantly increased. The proposed change does not reduce the performance requirements or acceptance criteria for the systems or components, therefore, the consequences of analyzed events are not affected. l l [ v' McGuire Units 1 and 2 Page 5663 of 6968 Supplement 25/20/97l
Containment Isolation valvee , Y Sc. lower Wr4med wh
/Rhsarteak MM f 30BVEIrzaarv - _-.. _ )
StstVII11ANCE FREQUENCY w<hunment) _
~
sa 3.6.3.1 verify each 6 purge valvekis sealed 31 days closed, emosyt for one purge valve in a g iL penetration flow path while in Condition I h . of this 140.
~
""~
_ _ hM.44duamikI
)
(Cea h r ha9 3 rr__ -- . b purper :- # .; w r) each(1814nc4 purgedv[ amp closea, Jr % j SR 3.6.3.2 except o.,
- - _ - - ae ,
valves are open sure control, s
. N[ , g
. ALama or air quality cons tions for
\// personnel entry, or for Survei - - - - - '"?
re the valves to be open. t-sa 3.6.3 g valves and blind flanges in high radiation _ ar .
}
areas may be verified by use of administrative controls. II verify each containment isolation manual 31 days G"g"4gQ t valve and blind f1= = that is located ou+=4d- -*=inmentfand requires to be ONMSM C talt E , * * - closed during accident conditions is l ,%edte Jm r'j" t closed, anoopt for containment isolation valves that are open under administrative controls. (continued) l 1 use-eas- 3.6-12 nov 1, 04/07/95 Mst.lb
- o. . ..,
I ON - Containment Isolation valves m___.=*r, 2.m ----__. a, = m=_1 3.6.3 SURVEILIANCE REQUIREIGNTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3 "JyE k valves and blind flanges in high radiation j areas may be verified by use of 1 administrative h j nute) Verify each containment isolation manual Prior to A valve and blind flange that is located entering N00E 4 OM M I'M8 l insice containmen M required to be from NODE 5 if s eg,1,J , ,,- closed duri W accident conditions is not performed a
' ow,uc st(***M )J closed, except for containment isolation within the valves that are open under administrative previous controls. 92 days MDVerify the 4=^1=tirm tima of f
In SR 3.6.3.[ accordance ( M te @ each automatiP oontainment I isolation valve is within limits, with the
, , Inservice stesting
%/
)\
h s ;----- -- . , _ . . - - -~ - _SR 3.6.3.6' Cy e each weight or spring I check 92 days Ive testable during operati one complete cycle of full tr 1, and verify each check valve closed when / $ the differential pressure the direction W of flow is 5 [1.2) paid opens when the differential pre.sure the direction of
/ flow is 2 [1.2) psi < [5.0) psid.
(continued) i l iN>e-STs- 3.6-13 Rev 1, 04/07/95 m4-c . l ____________.J
r 1 . Containment Isolation Valvesi J- ac
=
& + - w ric. Icar &==e. = =_1 3.6.3 SURVEIIJANCE EMJIRENDrFS (continued)
SURVEII. LANCE FREQUMCY x y - h Perform leakage rate testing for 184 days BR 3.6.3
~
containmant purgeyralves with resilient - y' 5* yol upper Comfo ret ...trf U ' ' O$ _. At 3- msf rw e r F roon ,,/ .Within 92 days after e opening g the valve 3R 3.6.3. Verify each automatic containment isolation valve that is not locked, sealed or t18K months Q otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal. O N3.6.3.9 Cy le each weight or spring inadad check !18 months Ive not testable during operation cae complete cycle of full travel, and verify each check valve remains cl when the differential pressure in the direction of flow is s [1.2) paid and when the differential pressure in the direction of flow is k [1.2) psid and
< [5.0) paid.
-- _) -
{ l ( j SR 3.6. 10 Verify ends ( ) inch containment purge [18) months A* valve is blocked to restrict the valve roa v I opening > (50]t. Q_ _f (ConH nnad)
,' f%
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contmiamant Isolation valves
-m.:;..__.,c,,_.______r -1 3.6.3 (A N .auh h 7
SENtVIILLABICE REQUIRBGMTS (continued) scRvrILIABICI ymmrwur'r r m
@gV verif the combined leakage rate foe all M i.
I SR 3.6.3. i e oc. building bypass leakage paths is- 3R 3.0.2 51, 44 when pressurized to R TAicA is not applicable n (P,is.tgy- , p
, r In nooordan'oe r * % with J (
10 CFR 50, Appendix J, as modified by approved exceptions
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Justificatten far Daviaticns S:cticn 3.6 - Rafcaling Operations I ( Q TECHNICAL SPECIFICATIONS
- 10. The changes are consistent with generic change TSTF-17 to NUREG-1431 I provided to NRC by the industry owners groups, except that an 18 month frequency, consistent with the current refuel cycle is proposed.
- 11. The changes are consistent with generic change TSTF-45 to NUREG-1431 provided to NRC by the industry owners groups.
- 12. The changes are consistent with generic change TSTF-30 to NUREG-1431 provided to NRC by the industry owners groups.
- 13. Not used.The containment upper compartment purge valve; arc automatic valvc =hich arc cl0:cd by a c0ntairment i0clation :tgn:1. Only manual valve and the containment 10 cr compart=cnt and instrument r00m purge valvc: are currently required to bc verificd cl;;cd Once per 31 days, therefore, the station i; n0t electing t0 add the NUREC SR 3.5.3.2 more rc;trictive rcquirement 10 verify that automatic containment i Olation valve: arc cl0;cd.
- 14. The NUREG SR 3.6.19.4 requirement to verify the system flowrate during the negative pressure test of the reactor building annulus is deleted.
Verification of flow rate is done by taking traverse measurements of the duct work and cannot be done in the short amount of time required to verify the negative pressure. This requirement is not in the current TS 4 and is not adopted in the proposed SR 3.6.16.2. System flowrates are verified during testing required by the Ventilation Filter Testing j Program. {
- 15. The changes are consistent with generic change TSTF-46 to NUREG-1431 provided to NRC by the industry owners groups.
- 16. STS 3.6.3 Required Action A allows check valves to be used to isolate on inoperable containment isolation volve. During development of the initial draft STS by the industry and NRC, the proof and review version of the STS required that the check volves be located inside containment. The industry provided coments (June 1991) which suggested that the words "inside containment" be removed since some plants were licensed prior to the issuance of the 10 CFR 50 Appendix A General Design Criteria. The GDC does not allow use of a check volve outside containment for containment ]
isolation. The reason provided by the industry for the requested change l is not applicable to McGuire or Catawba. Therefore, ITS 3.6.3 is proposed F consistent with the current licensing basis to require the check volve be N. inside containment before it can be credited as an isolation device. McGuire Units 1 and 2 23 Supplement 25/20/97 l t
O. ~ Containment _ Isolation ValvesJ Atmos,.w. h muT.mo3Dner1C . Ich I.imusinder. ARC I, ; W
. E 3.6.3 BASES 1
i ACTIONS _ L1 (continued) With the building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours. Restoration can be accomplished by isolating the penetration (s) that caused the limit to be exceeded by use of one closed and de-activated automatic V '. p valve, closed manual valve, or blind flange. idhen a d penetration is isolated the leakage rate for the isolated 0-Q penetration is asstaned to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is asst.. ed to be the lesser actual pathway leakaoe of the two device.. The 4 hour Completion Time is reasona61e considering the time required to restore the leakage by isolating the { penetration (s) and the relative importance of secondary ! containment bypass leakage to the overall containment- 1 _ function. _ E.1. El. and E.3 ([{P A QoWE In the event one or more[oM)pu%us%u. rge valvesAinneur one orom j more penetration flow patns are not within the purge valve leakage limits.Wve)1eakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers thatmeetthiscriterionarea(closedandde-activated
" automatic valve, closed manual valve, or blind flangel. A
" Dvalve with resilient seals utilized to satisfy VM A V red Action E.1 must have been demonstrated to meet the 1 requirements of SR 3.6.3.W me specmeo l Completion Time 's reasonable, considering that one I containment purge valve remains closed so that a gross breach of contaituent does not exist.
In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated __ following an accident, which are no longer capable of being - (continued) id80-STS- B 3.6-37 Rev 1, 04/07/95 MC.$w*v&
i V ContainmentIsolationValvesjAtmospne
^ A_mt m her1C. Ice WDnoenser, arr f 3.6.3 BASES ACTIONS E.1. E.2. and E.3 (continued) [ ~
~
// / automatically isolated, wil e in the isolation position Ne c I*, should an event occur. s Required Action does not u
- require any testino or alva manipulation. Rather, it 46 invoives verificatiort$throughla system walkdowrf, that those Anad ,. 1 solation oevices ouuioe containment capaDie of being d mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as ' prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the ;naccessibility of the isolation devices and other adninistrative controls that will ensure that isolation device misalignment is an unlikely possibility. Y n
for the containment purge valve with resilient seal that is isolatedinaccordancewithRequiredActionE.1,SR3.6.3.Q @ mustbeperformedatleastonceevery$921 days. This assures that degradation of the resilient seal is detected Wh l
/ and confirms that the leakage rate of the containment purge Q] valve does not increase during the time the_ penetration is isolated. normal Frequenc for dK a.o.a.s s cays, is baseo on NRC initiative, ric Issue B-20 (R f. 3).
Since more reliance is place on a single valve ile in . this Cond tion, it is pruden to perform the SR re often. Therefor , a frequency of ce per [92] days w s chosen andj has shown to be accep ble based on oper ing ( experi e. f F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCD does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 withi. 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) WOC STS- B 3.6-38 Rev 1, 04/07/95 k ,] Ac(wEr~&
V. Containment Isolation Valves . a me-w=.,c . ir,.____.:.,- . BASES (continued) @ (fr dia ter con, Aed ud m%u se*<f w] SURVEILLANCE SR 3.6.3.1 REQUIREENTS Each rari men containment purge valve is required to be. verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of. containment is not caused by an inadvertent or spurious of a conta purge valve. Detailed analysis of valves to conclusively demonstrate their abi <y to close ring a LOCA in time to limit offsite
$ , m,rn,mo g % dos Therefore, these valves are required to be in the see closed oosition during MODES 1, 2, 3, and 4. A
)' 'Cson_tassment punge) valve that is sealed closed a= st have X motive power to Ine valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term sealed" has no connotation of
-leak tightness. The Frequency is a result of an NRC initiative, Genaric Issue B-24 (Ref 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, O -
the Surveillance perwits opening one purge valve in a penetration flow path to perform repairs. EW ~ T 3.6.3.2 f. (L Q swepbf aa Ig%+ z / s - 1his SR ens es that t valves /are losea as red , if open, open or an allowable son. .If a I ger v ve is open in vi ation of this SR the valve is 9 red inoperable. the i rable lve is not 8 ot ise known to ha excessive eskage closed, it s 'g no considered to hav leakage outside o limits. The is t required to be when the n valves are or the reasons sta .. The valves be opened for pressure control, or air cpali considerations or , personnel entry, r for Surveil' anc s that require valves to be . The B alves are c 1 of j closing in the vironnen o ng a LOCA. ore, these valves re allowed to be for limited iods of time. The day Frequency is onsistent with o r taineen isolation valve r irements discus in 3.6.3. . - (continued) f,-t E ST; - B 3.6-39 Rev 1. 04/07/95
$4cbratvC.
v l V
Containment Isolation ValveSJ Atmosphe ~c g cunaunossnenc- ic# - we ma
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E' 3.6.3 BASG SURVEILLANCE SR 3.6.3 REQUIREMENTS (continued) This SR requires verification that each containment isolation manual valve and blind flange located outside containmentyand required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or cases outside of the containment boundary is within design limits. This SR does not require any testino or valve manipulation. Rather,[<=1 4 it involtes verificationgFthrough a system walkdowng that . Q,a capable of being mispositioned are in the correct position.thosecontainm {s4 Since verification of valve position for containment
@ m nulQ isolation valves outside containment is relatively easy, the @
31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are
/pf- / ade open under administrative controls are not required to meet gyy ~
the SR during the time the valves are open. Q ys a g
'f' # The Note applies to valves and blind flanges located in high
,3 L D O tri '5C > radiation areas and allows these devices to be verified (' closed by use of administrative maans. Allowing verification by administrative means is considerod" acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. 3 p)V T SR 3.6 3.
\
This SR requires veeification that each containment isolation manual valve and blind flange located inside containment imd required to be closed during accident conos 7ons is $1osed. The SR helps to ensure that post ace'edent leakage of radioactive fluids or gases outside of the containment boundary is within design limits, for containment isolation valves inside containment, the Frequency of
- prior to entering MODE 4 from K)DE 5 if not performed within the previous 92 days
- is appropriate since these containment isolation valves are operated under (continued)
E STS- B 3.6-40 Rev 1, 04/07/95 Mc6ru[r4
)
l Containment Isolation ValvesAAtmo cuoa7-nsnnw B 3.6.3 BASES W SURVEILLANCE SR 3.6.3. continued) REQUIREPENTS administrative controls and the probability of their i misalignment is low. The SR specifies that containment isolation valves that are open under cdministrative controls
- are not required to meet the SR during the time they are )
(pJyHT. f *
\ / This Note allows valves and blind flan s located in high radiation areas to be verified closed use of administrative means. Allowing verification by administrative seans is considered acceptable, since access to'these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once the have been verified to be in their proper position, is
? l e
/$ "' i SR 3.6.3J 1
Yerifying that the isolation time of eachroower operate @ automaticAcontainment isolation valve is within limits is h y required to demonstrate OPERABILITY. Le ir.olation time test ensures the valve will isolate in a time period less 6 srEc8 8 oft than or equal to that assumed in the safety analyses. (The
'g -g 66 0 isolation timeland Fre of this SR are in accordance 4 with the Inservice Testing rogram gr w e s .1, 1 SR 3.6.3.6/
In suba spheric containments, the check val s that serve a conta t isolation function are weight spring loaded to pro de positive closure in the direct 1 of flow. This ensur that these check valves will remai closed when the M) insi containment atmosphere returns to teospheric W c tions following a DBA. SR 3.6.3.6 ires ve fication of the operation of the k valves that are t . table during unit operation. The Fr of 92 days is sistent with the Inservice Testing rogram requirement or valve testing on a 92 day Freq y. (continued) q l M & STS- B 3.6-41 Rev 1, 04/07/95 7
%w'f ti i
ContainmentIsolationValvesjAtmMphernc s m sonerw. icsGnwrAnanualvQ {V B 3.6.3 _ r 7 te m . x, J tesk w rr h 4,- h BASES c 4 R p. g e 1. p e M
- d Lam.-t - v.i w r w a 5 0.07 L.
- (, ww ,,asunu) % Pa .-tu..mtssma SURVEILLANCE SR 3.6.3. I t.d.a r. k R c b ..A FE;p urrer e p M 9 3 " ' h 5 o.oi t REQUIREMENTS de-(continued) For containment purge valves with resilient seals $"""""1.hte. J additional leakage rate testing beyond the test requirements J of 10 CFR 50, Appendix J, is required to ensure OPERABILITY.(
Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due (e to the direct path between containment and the environment) a Freauency of 184 days was establishedEs- part of try NRO ) \ ' %j\r e (
' rest lution of Generic issueJ-20, ' Containment LeakpQe Due]
(to heal Deterioration" (Ref. 3). f -
'Additio ly, this SR -6st 6 nartormefwithin 92 gays atty o pen' the valvej The 92 day frequency was cnosen recognizing that cycling the valve could introduce
.- additional seal degradation (be T y m 6 A pury valve that has not been opened)Thus, .
yonddecreasing that occurring the to a
, c,,
interval (from 184 days) is a prudent measure after a valve p us8g.,A 4,,/.,.. v.tss nm.. t has been opened. % ,, ,,n,<r- r n en % ,In ctdeb 4'Ch
**'"' "*cl ins ' r .o n<3e. IoGrvr\ves eet room emparemain ri me n vpo. % ,f V c Wj b the.s r c eSoetsc3"6'3' @ I d ".^' " #~# '* ^ ""d t h U this SR m,st be recierne Q " % $"f**'i* W eve $y lhese valves, l cuerg 9A dqs a ft'^ Automatic containment isolation valves close on a - v ore ^*at; the d' V e- containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuatesignal.2 to its isolation $osition lanceonis anot cc,ntainment N M" .* bj 1 solation This survei required for valves that are locked, sealed, or otherwise secured in the 4Ta b '"J# I ttrc , Phasc. A , required The 05 is based h b6
[*[C g'l Dg
/ 1181 mont$osition under aditinistrative controls. Frequency Surveillance under the conditdces that apply during a plant outage and the potential for e.n u.splanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass this Surveillance when performed at the *181 month frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. (continued) /~'s E STS- B 3.6-42 Rev 1, 04/07/95 WG5c.
~
O. Containment, Isolation ValvesfAtm v--------- -- =~ ri gon=1 Q 8 3.6.3 BASES SURVEILLANCE SR -3.6.3.9 ~ \ REQUIRDENTS , _ (continued) In subatso ric containments,.the check valv s that serve a contai t isolation function are weight o spring loaded to provi positive closure in the direction f flow.' This.. ensures t these check valves will remain losed ehen the inside ontainment atmosphere returns to s teospheric condi ons following a DHA. SR 3.6.3.9 v ifies the oper ion of the check valves that are testable during uni operation. The frequency of 18 s is based on such' f ors as the inaccessibility of the valves, the fact t t the unit must be shut down to pe orm the tests, and successful results of the tests an 18 month basis during past unit operation. ( , SR 3.6.3.10 Reviewer's Not : This SR is only required for those uni with resilien seal purge valves allowed to be open duri [ MODE 1, 2 or 4] and having blocking devices on the O , _ valves that re not pennanently instclied. Verifying teach [42]inchcontainmentpurgevalv is blocked t restrict opening to s [50]% is required ensure t t the valves can close under DBA conditi s within the ti assumed in the analyses of References 1 nd 2. If a LOCA curs, the purge valves must close to mai ain conta t leakage within the values assumed i the acci analysis. At other times when purge alves are i red to be capable of closing (e.g., duri movement of i ir diated fuel assenblies), pressurnation rns are not sent, thus the purge valves can be fully . The month Frequency is appropriate because blocking ices are typically removed only during refueling outage. - SR 3.6.3-
^'@ @th,]-
l
, This SR ensures that the con 61ned leakage rate of all b buildi specifi ypass leakage paths is less than or equal to leakage rate. This provides assurance that the n h assueptions in the safety analysis are met. The leakage
- rate of each bypass leakage path is assumed to be the -
(continued) N B 3.6-43 Rev 1, 04/07/95
- it4C.6ulr <
7 Containment eIsolation ValvesjAtmosy=c}.1 h mat =n<fw . Ice CMrr . e - 8 3.6.3 BASES [ ' l SURVEILLANCE SR 3.6.3. d (continued) - REQUIREENTS maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, er blind flange. In this case, the leakage rate of the isolated bypass leaka path is assumed to be the actual pathway leakage thro the isolation device. If r both isolation valves in the penetration are closed, the
) actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maxista pathway leakage i is only to be used for this SR (i.e., Appendix J maxistm /
pathway leakage limits are to be quantified in accordance ( Qi kad nik witi Appendix J)_.JThe Frequencytis reauired by 10 CFR 50, g' E#g.** Id,J.bd b4 M je g, .. $ h t...t . AppenoixdasmodifiedbyapprovedexStions(a therefore, the Frequency extensions of 3.0.2 may not be %"'k " a g4g lJ.,5, wc.t,uo hen ) applied), since the testing is an Appendix J. Type test. E'E Ilj g,j g,t i. 3,,, / This SR simply imposes additional acceptance criteria. /c3l.h n.,' ' A c , ( ' ' f """ "] '"**
%JBv nass leakaoe is considered nart of L. IRev. sewer 4 GatetArnless soecifimr'W exempte@T) b$ '
. Sg.3.1,.O - -
- 1. @fSAR, Section115L J
f . @SAR, Section 16.28 1
. ric Issue B-20, 'Corgainment Leakage Due/t o Sej) erioration." e
- 4. Generic Issue B-24.
f 0.5. standeed wucuJ Fla n (,.R. C M m u;e .fo.3 % 7dthdu/ Sped $cddS, WN
.m C STS , 8 3.6-44 Rev 1, 04/07/95 Q .
jqc.4 w v b l
McGuire & Catawba Improved TS Review Comuments ITS Section 3.6, Containment Systems 3.6.3-10 DOC L.10 CTS 3.6.1.2 ACTION CTS 3.6.1.2 ACTION requires the combined bypass leakage rate to be within limits prior to increasing the RCS temperature above 200*F. Justification DOC L.10 states that no ACTIONS are specified if the unit is discovered outside the limits in MODES 1,2,3 or 4. This is not entirely correct. The actions to take in this situation is CTS 3.0.3. ITS 3.6.3 ACTION D is still considered a Less Restrictive (4 hours versus 1 hour allowed outage time) change. Comment: Revise DOC L.10 to address this aspect of this Less Restrictive change. DEC Response: DOC L.10 has been revised to reference CTS 3.0.3 as the current required action. O /\ mc3_cr_3.6 3.6-19 March 17, 1998
Discussicn of Chn g:s hetion 3.6 - C:ntainment Systems O G TECHNICAL CHANGES - LESS RESTRICTIVE
" isolation devices" is inserted for, " Valves and blind flanges" and retained in ITS 3.6.3 Action A.2, C.2, and E.2 Notes. This change modifies the existing technical requirements and is considered less restrictive. The change is consistent with NUREG-1431.
L.9 The time limitations applied to opening the containment purge valves in CTS 3.6.1.9.b and 4.6.1.9.2 are deleted from the TS. Limitations on the time the valves can remain open are based on the cumulative releases permitted by the radiological effluent monitoring program. The radiological effluent controls are described in ITS 5.5 and implement the requirements of 10 CFR 20. These requirements provide assurance that the doses to members of the public are controlled within specific limits. Therefore, the application of a predetermined time limit within the TS is not warranted. ITS SR 3.6.3.2 requires the volves be verified closed except for the reasons allowed in the CTS. Thus, use of the system wilI continue to be minimized and Iimited to specific reasons. In addition, these valves are fully qualified to close p in the required time upon receipt of a containment isolation V signal. The change is consistent with NUREG-1431. L.10 CTS 3.6.1.2 Action requires the combined bypass leakage rate to be within limits prior to increasing the Reactor Coolant System temperature above 200 *F. CTS 3.0.3 would be enteredN0 ccticr.: i cre :pecified if the unit is discovered outside the limits in MODES 1, 2, 3, or 4. ITS 3.6.3 Action D requires the combined bypass leakage rate limits to be restored within 4 hours in MODES 1, 2, 3, or 4. Allowing 4 hours to correct any bypass leakage limit problem provides an alternative to placing the plant in a shutdown evolution unnecessarily. This is acceptable because of the low probability of an accident occurring within this time period that could cause a radioactive release through the bypass leakage path. The change is consistent with NUREG-1431. L.11 A Note is added to CTS 3.6.4.2 Action to provide an exception to l Specification 3.0.4 that would allow Mode changes to be made with l one inoperable recombiner. The Note is appropriate since the other ! hydrogen recombiner remains available to perform the post accident ' function and since the hydrogen recombiners in no way affect l normal unit operation in MODES 1 and 2. This change, retained in j (q) ITS 3.6.7, is consistent with NUREG-1431. ) 1 McGuire Units 1 and 2 Page L - 45 Supplement 25/20/97l j
._..a
No Significcnt Hazards C:nsidIraticn S;cticn 3.6 - Crntainment Systems LESS RESTRICTIVE CHANGE L.10 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 3.6.1.2 Action requires the combined bypass leakage rate to be within limits prior to increasing the Peactor Coolant System temperature above 200 F. CTS 3.0.3 would be enteredNc ccticr.: cre specified if the unit is discovered outside the limits in MODES 1, 2, 3, or 4. ITS 3.6.3 Action D requires the combined bypass leakage rate limits to be restored within 4 hours in MODES 1, 2, 3, or 4. Allowing 4 hours to correct any bypass leakage limit problem provides an alternative to placing the plant in a shutdown evolution unnecessarily. This is acceptable because of the low probability of an accident occurring within this time period that could cause a radioactive release through the bypass leakage path. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion. I
- 1. Does the change involve a significant increase in the probability 1 or consequence of an accident previously evaluated'l The proposed change does not involve any hardware change. The secondary containment bypass leakage is not assumed in the initiation of any analyzed event. Allowing this leakage path to be outside its limits for 4 hours does not affect any assumptions of the accident analyses and still ensures corrective actions are performed. Thus, the consequences of an accident are not affected by this change. This change will not alter assumptions relative to an accident or transient event. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated.
(O , V McGuire Units 1 and 2 Page 2464 of 61M Supplement 25/20/Nl
l I l l McGuire & Catawba Improved TS Review Comments n ITS Section 3.6, Containment Systems 3.6.3-11 JFD Bases 4 STS B3.6.3 Bases - RA A.1 and A.2 STS B3.6.3 Bases - RA E.1, E.2 and E.3 STS B3.6.3 Bases - SR 3.6.3.3 ITS B3.6.3 Bases - RA A.1 and A.2 ITS B3.6.3 Bases - RA E.1, E.2 and E.3 ITS B3.6.3 Bases - SR 3.6.3.2 STS B3.6.3 Bases for RA A.; and A.2, RA E.1, E.2 and E.3 and SR 3.6.3.3 describe how ths verification of the correct position of the containment isolation valves is to be performed. This verification is performed via a system walkdown. The ITS modifies these Bases sections to state that the verification is "through administrative controls such as a system walkdown or computer status indication." The propos.sd cha1ge is unacceptable and changes the intent of the verification. The first part of the change (" administrative controls such as") would not limit the means of verification to only a system walkdown or computer status indication; a paper verification would be allowed by this change. This is unacceptable to the staff. In addition, no discussion or justification is provided to describe what is meant by computer status indication and why it is equivalent to a system walkdown; it is assumed that the computer status indication is merely a status listing (paper verification) which would be unacceptable. Comment: Delete both parts of this change, or provide additional discussion and justification p to show that the computer status indication is the equivalent of a system walkdown. ( l bl DEC Response: The proposed Bases have been revised to eliminate a reference to administrative controls. The CTS requires that valve posl tion be verified but does not specify the methods for performing the verification. The operator' aid computer (OAC) and control board indications provide the operator with vaive position status for a number of valves. These indications are contidored equivalent to a system walkdown for the purposes of verifying system alignment. Therefore, the proposed ITS Bases which allows computer status indication for determining valve position is acceptable and consistent with the current requirements. Valves which do not have control room status indication are verified through system walkdowns. i p (j mc3_cr_3.6 3.6-20 March 12, 1998 l l d
.q Containment Isolation Valves B 3.6.3 BASES L
ACTIONS A.1 and A.2 ! (continued)- ! In the event one containment isolation valve in one or more penetration flow paths is inoperable except for purge valve or reactor building bypass leakage not within limit, the affected penetration flaw path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by.a single active failure.- Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation j valve, a closed manual valve, a blind flange, and a check ' valve inside containment with flow through the valve . secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and O that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be I verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Ranher. it involves verificationthroughgdmintserative cantM4. sucD T Oas a system walkdown'iir computer status indication', that
'tWose isolation devices outside containment and capable of being mispositioned are in the correct position. The Completien Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineerti.g judgment and is considered reasonable in view of
.'the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment'is in unlikely possibility'.
(continued) McGuire Unit 1 B 3.6-19 . gypp6VL _ 5/20/97 -
Containment Isolation Valves B 3.6.3 BASES ACTIONS E.1. E.2. and E.3 (continued) In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being .i automatically isolated, will be in the isolation position I should an event occur. This Required Action does not i require any testing or valve manipulation. Rather. it involves verificatiogthrough afRniaef'he re-+4 e4h
@ a system walkdownTr computer status indication, that those isolation devices outside containment capable of being i mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on er.gireering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unitkely possibility.
i for the containment purge valve with resilient seal that is isolated in accordance with Required Action E.1, SR 3.6.3. must be perfonned at least once every 92 days. This assures that degradation of the resilient seal is detected and confinns that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. F.1 and F.2 ! If the Required Actions and associated Completion Times are l not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) McGuire Unit 1 B 3.6-23 JvppM L.";/G/97
Containment Isolatien Valves B 3.6.3 BASES (continued); SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been perforined. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have sotive power to the valve operator removed. This can be accomplished by de-energizing the ; source of electric power or by removing the air supply to ; the valve operator. In this application, the term " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry ; into Condition E, the Surveillance permits opening one purge o l
& valve in a penetration flow path to perform repairs.
SR 3.6.3.83)l This SR requires verification that each containment isolation manual valve and blind flange located outside containment 1and not locked, sealed, or otherwise secured and
"*" )g required to be closed during accident conditions is closed.
The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather it involves vertf1catiosyhroughC;ni,crinwe mo6trols. such at a l system walkcown or conputer sdtus indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. .Since ve-ification of valve position for containment isolation valves outside containment is relatively easy, the 31 day frequency is based on engineering judgment and was chosen to 4 provide added assurance of the correct positions. The SR. ' specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not (continued) McGuire Unit 1' B 3.6-24 M ' i/25/97
Containment Isolation Valves B 3.6.3
~
BASES ACTIONS A.1 and A.2
-(continued)
In the event one containment isolation valve in one or more penetration flow paths is inoperable except for purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check 1 valve inside containment with flow through the valve
~
secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closect available one to containment. Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable.- considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1, the affecteo penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an "cident and no longer capable of being automatica1,1y isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device _ manipulation. Rather, it involves verificatiogrj)through amilHnrecrhive contron, suc) 1 a system walkdown Yr computer status indication, that j
@t hose isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of
..the inaccessibility of the isolation devices and other administrative ' controls that will ensure that isolation device misalignment is an unlikely possibility.
(continued) McGuire Unit 2 8 3.6-19 p q ol M L _5/20/97-
Containment Isolation Valves - B 3.6.3
~
BASES ACTIONS E.1. E.2. and E.3 (continued) In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it _. involves verificatiogthrough (gminuwadwtontnn scauca
@ a system walkdown or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure tLat isolation device misalignment is an unlikely possibility.
O For the containment purge valve with resilient seal that isf isolated in accordance with Required Action E.1, SR 3.6.3.5W must be performed at least once every 92 days. This assures I that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least. MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) McGuire Unit 2 B 3.6-23 SvppkFL'/2G/;7,
Containment Is21ation Valvss B 3.6.3 C BASES (continued) SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gn>ss breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been perfonned. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by mmoving the air supply to the valve operator. In this appitcation, the term " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance pennits opening one purge valve in a penetration flow path to perfonn repairs. O E& SR 3.6.3.@ j This SR requires verification that each containment isolation manual valve and blind flange located outside containmentyand not locked, sealed, or otherwise secured and Qya required to be closed during accident conditions is closed. l The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment 3 boundary is within design limits. This SR does not require j any testing or valve manipulation. Rather, it involves verificati through d*=fn=reuve -A -nAs a g system walk or computer status indication, that those , containment isolation valves outside containment and capable of being mispositioned am in the correct position. Since verification of valve position for containment isolation ' valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to pmvide added assurance of the correct ;ositions. The SR specifies that containment isolation vaives that are open ) under administrative controls are not required to meet the SR during the time the valves are open. This SR does not (continued) McGuire Unit 2 8 3.6-24 g Q 'L- ='/20/;F
p ContainmentIsolationValvesfAtmos cT ouoatapspneric, ice G6noenser. a 1)l % B 3.6.3 BASES ACTIONS A.1 and A.2 (continued) failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valgit, a closed manual valve, a blind flange, and a check h- - w valve 1with flow through the valve secured. For a penetration flow path isolated in accordance with Required
, 6fs - .os cor;<A #3L ' Action A.1, the device used to isolate the penetration
- should be the closest available one to containment.
Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required (. to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation
, , position should an event occur. This Required Action does not require any testina or device manipulation. Rather, it g '
, c ^^( y7 r isolation oevices outsioe contau. n ano capanie of beingg e wer re-m~Han i orc-9k 'A 5 3/ mispositionedareinthecorrect$osition. The Completion c
Time of 'once per 31 days for iso ation devices outside "bSM a containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as
" prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days' is ba::xf on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves. For penetration flow paths with only one containment isolation valve and a closed system, Condition C provides the appropriate actions. (continued) n MC ';is 8 3.6-34 Rev 1, 04/07/95 N3u1Yf)-
O. Containment Isolation ValvesJ Atmospne qmawanrier ic. ice AmnDenser. anc na E 3.6.3 BASES ACTIONS E.1. E.2. and E.3 (continued) 1 CT ~ bintheisolationposition automatically isolated, w'
*, should an event occur. is Required Action does not
% < t- a require any testino or alwa manipulation. Rather. it 3 3 invoives ver1ticatior$ through> a system walkdow(, that those p.a;u g,,[.a,
.,. p,, 1solanon ownces oumae wi a1,
. c.4 e of being mispositioned are in the correct position. For the isolation devices inside containment, the time oeriod specified as " prior to entering MODE 4 from 100E 5 if not perfonned within the previous 92 days' is based on engineering judgment and is considered reasonable in view of the :naccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.
For the containment purge valve with resilient seal that i isolated in accordance with Required Action E.1, SR 3.6.3 @ must be performed at least once everyJL9?2 days. This assures that degradation of the resilient seal is detected
@ f and confims that the leakage rate of the containment purge O valve does not increase during the time the penetration is isolated.
baseo on normal Frequenc for .w 3.o.3.7, i cays, 1s NRC initiative, ric Issue B-20 ( f. 3). Since more reliance is plac on a single valve ile in - this Cond tion, it is pruden to perfonn the SR re often. Therefor , a Frequency of e per [92] days chosen andj has shown to be accep le based on oper ing (
.experi .f F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCD does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the r ired plant conditions from full power conditions in an o rly manner and without challenging plant systems.
(continued) idGlHifer B 3.6-38 Rev 1, 04/07/95-hGw'r6 , 4
O- Containment Isolation Valves] Q n-_ - = E 3.6.3 - BASES
~
1 SLRVEIllAICE SR 3.6.3 l IREENTS tinued) This SR requires verification that each containment isolation manual valve and blind flange located outside containmentyand required to be closed during accident conritions is closed. The SR he s to ensure that post accident leakage of radioactive uids or ses outside of the containment boundary is within design inits. This SR does not require any testino or valve manipulation. Rather.[ad.
- it involles verificationg>tthrough a system walkdowg_ that _ <t I those containment isolation valves outside containment ana ~ ,, g ,q capable of being mispositioned are in the correct position. g.g Since verification of valve position for containment Q n%l@
isolation valves outside contairunent is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions.
- ~ ~
The SR specifies that contairunent isolation valves that are on/ /edek'k open under administrative controls are not required to meet the SR during the time the valves are open. g ,e g$ g g-M 'M' N The Note applies to valves and blind flanges located in high O radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered" acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misali t of these containment isolation valves, once have been verified to be in the proper position, is small. 3 SR 3.6.3 3 I This SR requires we'ification that each containment isolation manual valve and blind flange located inside containmenttiend required to be closed during accident
- canaistoris is closed. The SR he s to ensure that post accident leakage of radioactive uids or gases outside of the containment boundary is within design limits. For.
. containment isolation valves inside containment, the Frequency of
- prior to entering _ MODE 4 from N)DE 5 if not perfonned within the previous 92 days' is appropriate since these contaifunent isolation valves are operated under (continued) 100 CS B 3.6-40 Rev 1, 04/07/95 NC6tutY
1
)
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.3-12 CTS 4.6.1.9.1 ITS SR 3.6.3.1 and Associated Bases CTS 4.6.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room (McGuire and Catawba), and the upper compartment and the hydrogen purge system (Catawba only) are sealed closed. ITS SR 3.6.3.1 verifies that these valves are sealed closed but provides an exception to open one purge valve in a penetration flow path while in Condition E of ITS 3.6.3 to pedorm repairs. This exception could not be found in the CTS markup and no justification was provided for this Less Restrictive change. Comment: 1 Revise the CTS markup to show this exception and provide the appropriate discussion and i justification for this Less Restrictive change. DEC Response: DOC L.30 has been added to justify this allowance and the CTS has been annotated accordingly. l t
!g mc3_cr_3.6 3.6-21 March 12, 1998 i
- E CONUINMENT 61EfiiBf( Edu#s# VAv69 ,
diiRVFillANCEArnuitgerfD SA S.G.S.( ~ EET2 Each containment purge ---iy
===ar ====- mur= valve (s) for k the lower compartment and instrument room shall be verified to be sealed closed at least once p+r 31 dayss v _WN4 he 0" FM
<j yy l'a a penc k %
.6. .Z Ike c ttwe tise t .contai purge s y and/o l 4 . s p A w (;Ig 4 st isolat alves for th er compa t.have b _open durin G"4 '. E *g fb.'
=adar wea" 11 be'detaint at least ~ner 7 s ss s.t. x vJ p @ O-m #ZF -
At least once per'@ll months (GrJr ST59ERED TESFBAlbch-str a ; let containment porge W'- ^ ="-noimuum mire swi- Iouer c_capartment and lastrument room with resilient material seals (sk n, - { FirrNii!MWMairo"Upgf","";'"," Z,';g" '"- a s.t.. t Kvi- ]ast' once per 3.monthsC aineen e r-i ;, a i . ,.- h i Ee unner compartment resilient material J seals fshpfl be essonMted OPERASG)pr veniy y _n a r rne --.i---- rate is less team v.v2 L g restur red to - s.w J @ u yace m (, s& McGUIRE - UNIT 1 3/4 6-14 Amendment No. 166 0 Y..qe to of/2-
ff'O Sct/uo k 3.6 3 kaanon vaLvG,) Isus(EILLaerofE0 tift 9EffD - I# F 4 3./ . GI23 Each contatament purF valve (s) fin i the lower compartment and instrument room shall be ve_rified to be sealed l L. 36 Aceib*atP l closed at 1.past once per 31 dayst e u g.,s 1t 1 2 e A bJ TAiti deis @~ F 4 G M p?!grs.t d ci, r - - an = w,s.e.,5,Yg s.o me==23 CEI
,c tAt least inunt p rponce ppeasqup
_ . . wear . . = s'Emig
. __. __n.2ggy.gsg
& 3 ,7
-N 6 te. y.p c instrument with restilent meterial suis spa n m mesured Makaartwhy d s k
- w .4 4 -j _tra .
h "'"- z +. 5 4D m . ieast e. ,e+ 3.e rwet=at N4mhup,*% uw 3 q hsys ta,ilf#"re'sTifat - =t.rsai j g'" m ....iggg
, .....,e-_.... tne x9 & (
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0 0 0 4 e i MdillIRE - INIIT 2 3/4614 %g , Pqc. /0 d/2. e e
Discussicn cf Ch nges 5:ction 3.6 - C:ntainment Systems O TECHNICAL CHANGES - LESS RESTRICTIVE V L.27 CTS 3.6.4.3 does not include an Action for the Condition where there is no OPERABLE hydrogen igniter in one containment region. ITS 3.6.9 adds this new condition and requires a hydrogen igniter be restored in the affected containment region to OPERABLE status within 7 days or be in MODE 3 within 6 hours. This change provides actions consistent with a footnote to CTS Surveillance 4.6.4.3.a which requires that inoperable igniters not be on redundant circuits in the same region. CTS 3.0.3 would be required to be entered if this condition existed in the CTS. This change is acceptable because of the low probability of an event occurring within the 7 day completion time that would generate an amount of hydrogen that exceeds the flammability limit and the availability of the hydrogen recombiners, hydrogen skimmers, and hydrogen monitors. This change is consistent with NUREG-1431. L.28 CTS 4.6.3.2, 4.6.2.c, 4.6.5.6.1.a. 4.6.5.6.1.d, and 4.6.1.8.d.2 require that the specified testing be performed using a " test" signal. ITS SRs 3.6.3.76, 3.6.6.3, 3.6.6.4, 3.6.8.4, 3.6.10.3, l 3.6.11.1 and 3.6.11.3 permit the use of an actual or simulated D actuation signal for testing purposes. This change permits credit ( . to be taken for unplanned events (actual signals) which provide the necessary data to satisfy the SRs. The actual signal is what is credited within the safety analysis and is sufficient for demonstrating compliance with the SRs. This change is consistent with NUREG-1431. L.29 CTS 4. 6. 5. 3.1. 0 requires continuously monitoring inlet door pasitions. ITS SR 3.6.13.1 requires the door pasitton be monitored every 12 hours. Continuous monitoring of inlet door position is accomplished by the Inlet Door Position Monitoring Sys tem, CTS 3. 6. 5. 4. This specification, however, is relocated from the TS as discussed in R.2. The requirement of 12 hours is a less restrictive change. The proposed change is acceptable since the 12 hours is consistent with the monitoring of ice bed temperature which is the parameter of concern with an open door. L.30 CTS 4.C.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room are sealed closed. ITS SR 3.6.3.1 verifies that these volves are sealed closed but provides an exception to open one purge volve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs.
\ The exception was added to establish the allowance of opening a
<G McGuire Units 1 and 2 Page L - 10M Supplement 25/20/97l
r-biscussien cf Ching2s Section 3.6 - Cantainmext Systems TECHNICAL CHANGES - LESS RESTRICTIVE valve under administrative controls when it is required to be closed or declared inoperable to comply with ACTIONS. This exception is necessary to establish a concept that although utilized, is not formally recognized in the present Technical Specifications. Without the allowance, necessary repairs and testing could not be performed and the equipment would not be able to be restored to OPERABLE status. This change is consistent with NUREG-1431. L.31 CTS 4.6.1.1.a and on associated footnote allows certain containment isolation valves to be opened under administrative control. ITS 3.6.3 includes a note to the ACTIONS which provides an allowance to open any containment isolation valve required to. be closed (except for the large containment purge / exhaust valves) under administrative controls. This is acceptable based on the administrative controls consisting of a dedicated operator at the valve in continuous communication with the control room, or for valves with controls in the control room, a monitoring of containment isolation signal status. These controls provide protection equivalent to the automatic isolation system. The
\ large purge / exhaust valves are addressed by DOC L.30.
L.32 CTS 3.6.1.9 ACTION c requires restoring the inoperable valves to OPERABLE status. ITS 3.6.2 Required Action E.1 specifies isolating the affected penetration flow path by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange. The proposed change is a less Restrictive change in that the CTS only allowed valve restoration to OPERABLE status, not penetration isolation. Isolating the offected penetration ensures the penetrotton flow path is performing its safety function and is an appropriate compensatory action. This change is consistent with NUREG-1431.
~
L.33 CTS Surveillance Requirement 4.6.1.1.c contains details and requirements for Type B leak rate testing for penetrations which have been opened after testing. ITS SR 3.6.1.2 contains the broader requirement that all applicable Type B testing specified by 10 CFR 50, Appendix J, Option A must be met. The CTS requirement duplicates the requirements of 10 CFR 50, Appendix J, Option A section III.D.2 which requires that Type B penetrations be retested foilowing opening. This change is acceptable since it
.[j-u McGuire Units I and 2 Pace L - 115 Supplement 25/20/97l l i
~
N3 Signific nt HIz:rds C:nsidsriticn Sectien 3.6 - Containment Systems LESS RESTRICTIVE CHANGE L.30 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room are sealed closed. ITS SR 3.6.3.1 verifies that these valves are sealed closed but provides on exceptica to open one purge volve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs. The exception was added to establish the allowance of opening a valve under administrative controls when it is required to be closed or declared inoperable to comply with ACTIONS. This ) exception is necessary to establish a concept that although l utilized, is not formally recognized in the present Technical Specifications. Without the allowance, necessary repairs and testing could not be performed and the equipment would not be able to be restored to OPERABLE status. This change is consistent with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an occident previously evaluated? l The proposed change allows a single volve in a penetration to be opened to conduct repairs or demonstrate the operability of that volve or the remaining volve in the penetration. The purge valves are 'not assumed to be the initiators for any analyzed event.
Therefore the probability of an accident previously evaluated is not significantly. Additionally, the consequences of an event occurring with the component inoperable in accordance with the allowance is the same as the consequences of an event occurring with the component inoperable for the current allowable outage time. Therefore, the proposed change will not involve a significant increase in the probability or consequences of an O accident previously evaluated. b McGuire Units 1 and 2 Page 6064 of 6564 Supplement 25/20/97l 1 f I
N2 Significant Nazards'Crnsidsratien S:cticn 3.6 - C ntainment Systems
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The possibility of a new or different kind of accident from any accident previously evaluated is not created because the proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant.
- 3. Does this change involve a significant reduction in the margin of safety?
This change allows performance of testing or repairs required to demonstrate operability, which otherwise could not be performed because of the requirements of the associated actions. The change may permit the plant to recover from the inoperable condition, and fully restore redundancy to the associated penetration. No safety limits, operating parameters or setpoints are affected by this change therefore there will no reduction in the margin of safety. O O McGuire Units 1 and 2 Page 6164 of 6564 Supplement 23/20/97l
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.5 2 JFD Bases 3 (Catawba) JFD Bases 4 (McGuire) STS B3.6.5 Bases - SR 3.6.5.1 and SR 3.6.5.2 ITS B3.6.5 Bases - SR 3.6.5.1 and SR 3.6.5.2 STS B3.6.5 Bases - SR 3.6.5.1 and SR 3.6.5.2 states that "The 24 hour Frequency for these SRs is considered acceptable based on observing slow rates of temperature increase within containment as a result of environmental heat sources (due to the large volume of the containment)." This material has not been adopted in the Bases for ITS B3.6.5. Justification JFD Bases 3 (Catawba) and JFD Bases 4 (McGuire) do not specifically address this proposed deletion, and give different justifications for the same change. Comment: Provide additional discussion and justification to show why this STS statement is not applicable to McGuire and Catawba and revise the ITS Bases markup accordingly. DEC Response: The surveillance frequency is adequately justified by other statements in the STS Bases. This statement is not considered accurate since ice condenser containments are relatively small in comparison to other containment types. This appears to be a carryover statement from the other containment designs included in the STS which do have large free volumes. JFD 13 has been added to justify this deletion. O mc3_c r_3.6 - 3.6-25 March 12, 1998
g. Containment Air Terperature (IceAhmetu 8 3.6.!i$ Q BASES
~
ACTIONS B 1 and B.2 (continued) does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based en cperating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6 8it.1 and SR 3.6.58.2 @ REQUIREMENTS Verifying that containment average air temperature is within the t.00 limits ensures that containment operation remains within the limits assumed for the containment analyses. In gg, jog order to determine the contairunent everage air tenperature, f
/
weighted average)is calculated using reasurements taken at [e S4 7fdAe 4 M " 4 / locations within the containment selected to provide a
'"* *"*' **"**'"*'"' =ccans
</~d "'/ '***"'
ine c* nuurrequen c'y' ** theset Nss u vvun u.
.}basedon oserved s' rates of emperature nerease w se' in f'
contai t as a sult of en ronmental t source (due f] .to t lerne vol of c t). F reore 24 hour Frequency is consloered adequate in view o other (vf indications available in the control room, including alarms, to alert the operator to an abnormal containment temerature condition REFERENCES 1.@SAR,Sectionf6.?A. h 2, 10 CFR 50.49. 4 I
/) GCA. 60. Slag NcArsoce. t' }te Acgtevts,(C )(2)kh B 3.6-59 Rev 1, 04/07/95 4 W .sfS-HC fga.or*G
'{m \. v'
Justific:tica fcr Devictions Section 3.6 - Refueling Operations BASES
- 10. The changes are consistent with generic change TSTF-17 to NUREG-1431 provided to NRC by the industry owners groups, except that an 18 month frequency, consistent with the current refuel cycle is proposed.
- 11. The discussion in the NUREG 3.6.16 Bases for Actions B.1, B.2, C.1 and C.2 are incomplete and not consistent with the Specification nor with the rules of completion times as defined in NUREG Section 1.3. The discussion indicates that Condition C is only entered for limited cases of not meeting required Action B.1. This is not represented in the specifications and is also not consistent with the first sentence in the Bases discussion for C.1 and C.2. The Bases for ITS 3.6.13 provides the missing detail and removes the incorrect discussions.
- 12. The changes are consistent with generic change TSTF-30 to NUREG-1431 provided to NRC by the industry owners groups.
- 13. NUREG Bases for SR 3.6.Sb.1 states that the 24 hour frequency for the containment air temperature survetIlances is acceptable in part based on the slow temperature changes due to the large volume of containment. This
?) statement is not adopted in ITS Bases for SR 3.6.5.1. For ice condenser NJ containments, the containment volume is relatively small. The statement apparently is a carryover from the NUREG Bases for other containment designs which do have large free volumes (e.g. atmospheric, dual, subatmospheric). The remaining statements in the NUREG Bases provide sufficient justification for the frequency without reliance on this statement. g G McGuire Units 1 and 2 23 Supplement 25/20/07 l
McGuire & Catawba Improved TS Iteview Comuments ITS Section 3.6, Containment Systems O 3.6.6 Containment Spray System 3.6.6-1 DOC A.18 CTS 4.6.2.c ITS SR 3.6.6.3 ITS SR 3.6.6.4 CTS 4.6.2.c is revised to include a clarification that valves which are locked, sealed, or otherwise secured in their required safety position are not required to be verified that it actuates to its correct position on an actuation signal. This change is designated as DOC A.18 in the CTS markup. The justification and discussion for DOC A.18 states that this change is retained in ITS SR 3.6.6.3 and SR 3.6.6.4. ITS SR 3.6.6.4 deals with verifying pump actuation not valve actuation. Thus DOC A.18 is not applicable to ITS SR 3.6.6.4. See Comment Number 3.6.3- 6 for additional comments on DOC A.18. Comment: Revise justification DOC A.18 to delete the reference to ITS SR 3.6.6.4. See Comment Number i 3.6.3- 6. I DEC Response: DOC A.18 has been revised to delete the reference to ITS SR 3.6.6.4. i O o .V mc3_cr_3.6 3.6-26 March 12, 1998 l
Disc:ssicn cf Ch nges Sectica 3.6 - Cont':inment Systems ADMINISTRATIVE CHANGES These changes, retained in ITS SR 3.6.3.76, 3.6.6.3, 3.6.3.3 and 3.6.36.4, are consistent with NUREG-1431. A.19 CTS LCOs 3.6.3 and 3.6.1.9 are being combined into ITS LC0 3.6.3," Containment Isolation Valves". The two CTS LCOs duplicate the requirements for the valves used for containment penetration flow path isolation. Since the wording of CTS LC0 3.6.1.9 is repeated in the Action, it is eliminated. Minor wording modifications are made in combining the LCOs, but these changes do not alter the technical requirements. This change is considered administrative and is consistent with NUREG-1431. A.20 Not used. CTS 3.5.1.0 f.ction c require; incperable valves be rc;tcred to CPEP/SLE statu dithin 24 hour;. ITS 3.5.3 f,ction E requirc; the :::c valves to be incl:ted by u;c cf at ic :t One cic;cd and dc activated catcmatic valve, cic;cd manual salve, er b?ind !? ngc. hclating contairment pcnctraticn valvc cn;urc: the vahc h perfc:-ing its : fety function and i: On approprint: compen;;tcry action. Thh ch ng: B considered On Od=inhtrative ( change and b con:htent . ith N'JREC 1431. ( A.21 Not used. A.22 CTS 4.6.2.c.3 and 4.6.5.6.2 require that system functions in response to the Containment Pressure Control System (CPCS) be verified. CTS 4.6.5.6.1.f refers to a required start permissive signal for hydrogen skimers but does not state the source. ITS 3.6.6, 3.6.8, and 3.6.11 surveillance requirements provide the specific requirements to be verified and refer to the start permissive and terminate signals of the CPCS. The setpoints are already specified in CTS 3.3.2 and retained in ITS 3.3.2. This change does not alter any surveillance requirements and is therefore considered an administrative change. A.23 Not used. A.24 CTS LC0 3.6.1.8 Action b allows the ventilation system heaters to be inoperable up to 7 days and allows continued operation of the ; system provided a report is made to the NRC within 30 days. The report is required to state the reason for the inoperability and -s the planned actions to return the heaters to operable status.
\
This allowance is reformatted and retained as ITS 3.6.10 Action B. Id McGuire Units 1 and 2 Page A - 67 Supplement 26/20/97l
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems O 3.6.6-2 DOC LA.9 JFD Bases 3 JFD Bases 4 CTS 3.6.2 ITS B3.6.6 Bases - BACKGROUND ITS B3.6.6 Bases - LCO CTS 3.6.2 states that the Containment Spray System shall be capable of taking suction from the refueling water storage tank and transferring suction to the ontainment sump. This LCO statement implies that the transfer is automatic. This information is being relocated to tho Bases by DOC LA.9 which is acceptable. However, the Bases statements in ITS B3.6.6
. Bases - BACKGROUND and LCO sections which discuss this transfer mechanism state that the transfer is done manually. The discussion associated with DOC LA.9 does not describe this change from an automatic transfer to manual transfer. Comment: Provide additional discussion and justification to show that the change from the CTS automatic transfer requirement to the ITS manual transfer requirement is appropriate based on current licensing basis, system design or operational constraints.
DEC Response: Duke Energy disagrees with this interpretation of the existing licensing basis. The transfer
- steps for the containment spray system have always been a manual function. The required steps to accomplish the switchover process are described in McGuire FSAR Table 6-125 and Catawba FSAR Table 6-93. The Bases discussion is consistent with the existing licensing basis, therefore, no additional discussions are required in DOC LA.9.
mc3_cr_3.6 3.6-27 March 12, 1998
l McGuire & Catawba Improved TS Review Comments Q ITS Section 3.6, Containment Systems V 3.6.6-3 JFD Bases 4 l ITS B3.6.6 Bases BACKGROUND l The discussion for ITS B3.6.6 Bases BACKGROUND states in the insert on Page 83.6-87 that the ph of the sump solution is raised to at least 8.0 within one hour of the onset of the LOCA. The insert material also states that the chemical mixing tank and the charging pumps are used to accomplish this but it does not describe how this accomplished. Comment: Revise ITS B3.6.6 Bases BACKGROUND insert discussion to address this issue. DEC Response: This discussion has been misinterpreted. The resultant pH of the sump solution is based on the mixing of the RCS fluids, ECCS injection fluid, and the melted ice which are combined in the sump as a result of a postulated pipe break and subsequent blowdown. The ITS Bases insert materialindicates that it is also possible to adjust this resultant pH using the charging pumps and mixing tanks. The procedural details of how this is accomplished are not relevant to this Bases discussion for the containment spray system and are a level of detail not consistent with the STS Bases for the generic material which was replaced with plant specific material. O i l i mc3_cr_3.6 3.6-26 March 12, 1998
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.6-4 JFD Bases 4 STS B3.6.6 Bases - SR 3.6.6.1 ITS B3.6.6 Bases - SR 3.6.6.1 STS/ITS SR 3.6.6.1 verifies that each containment spray manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. STS B3.6.6C Bases-SR 3.6.6C.1 states that this verification is to be accomplished by a system walkdown for those valves outside containment. ITS B3.6.6 Bases
- SR 3.6.6.1 modifies the STS wording to allow Administrative controls to be used for the verification. The Administrative controls would include a system walkdown, but would also allow a paper verification, a computer status indication or any other administrative means of verifying valve position. This change significantly modifies the intent of the SR. See Comment Number 3.6.3-11. Comment: See Comment Number 3.6.3-11.
DEC Response: The proposed Bases have been revised to eliminate a reference to administrative controls. The CTS requires that valve position be verified but does not specify the methods for performing the verification. The operator aid computer (OAC) and control board indications provide the operator with valve position status for a number of valves. These indications are considered equivalent to a system walkdown for the purposes of verifying system alignment. O Therefore, the proposed ITS Bases which allows computer status indication for determining valve position is acceptable and consistent with the current requirements. Valves which do not have control room status indication are verified through system walkdowns. i
/~%
( mc3_cr_3.6 3.6-29 March 12, 1998 1
Containment Spray Systerr. B 3.6.6 BASES ACTIONS B.1 and B.2 (continued) If the affected containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Times are reasonable, . based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. . Rather. it involves verificatio through Gdminntrativexontrols, s4c)
@ a system walkdown@or computer status indication, that those valves outside containment and capable of potentially being mispositioned, are in the correct position.
SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design cury.e and is l indicative of overall perfonnance. Such inservice inspections confirm component OPERABILITY, trend
;G (continued)
McGuire Unit 1- B 3.6-43 SvppWL 5/2^/W
Containmec*
- pray System B 3.6.6 O' .
BASES:
-ACTIONS B.1 and B.2-(continued)
If the affected containment spray train cannot be restored to OPERABLE status within the required Com)1etion Time, the plant must be brought to a MODE in which tie LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6' hours and to MODE 5 within 84 hours.. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging' plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driv 11;g force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS - Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the O Containment Spray System provides assurance that tha-pr;oper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verificatiornthrough admiem - -trolsrsucTD
@ a system walkdown 'Br computer status indication - that those valves outside containment and capable of potentially being mispositioned, are in the correct position.
SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential head are nonnal tests of centrifugal pump perfonnance required by Section XI of the ASME Code (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confinns one point on the pump design curve and is indicative of overall perfonnance. Such inservice
' inspections confinn component OPERABILITY, trend (continued)
~McGuire Unit 2 8 3.6-43 J,gf%V2 5/20/97
. . . ~ . .. . - . . . .
I I Containment Spray System (I2e condensers @ B 3.6.60 BASES ACTIONS B.1 and B.2 (continued) If the affected containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Conpletion Times are reasonable,. based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenoing plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. SURVEILLANCE SR 3.6.60.1 REQUIREMENTS Verifying the correct alignment of manual, power operated. O and automatic valves, excluding check valves, in the ij Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or
' j ' ctherwise secured in position since they were verified in
- the correct position prior to being secured. This SR does a i not require any testina or valve manipulation. Rather, it g- ,
L involves verificatiormthroughle system walkdowrg that those valves outstae contai t and capable of potentially being l , [MDy$Agif .
' ) mispositioned, are in he correct position.
Tgr SR 3.6.68.2 Verifying that each containment spre.y pump's developed head at the flow test point is greater than or equal to the j required developed head ensures that spray pump perfonnance ti has not degraded during the cycle. Flow and differen Mal performance T head arebynonnal required Sectiontests of centrifugal XI of the ASME Codepump (Ref.9). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the punp design curve and is indicative of overall performance. Such inservice inspections confinn conponent OPERABILITY, trend (continued) i
-W9GHiTS- B 3.6-91 Rev 1, 04/07/95 y,o e i
i
McGuire & Catawba Improved TS Review Comuments ITS Section 3.6, Containment Systems STS 3.6.7 Spray Additive System (WicGuire Only) S3.6.7-1 JFD - None STS 3.6.7 and Associated Bases STS 3.6.7 " Spray Additive System" is not included in the McGuire ITS. No justification is provided to justify its deletion from the McGuire ITS. Comment: Provide a discussion and justification for the deletion of this specification from the McGuire ITS. Revise the ITS markup appropriately. DEC Response: This system is not part of the design at either station. The STS markup for McGuire has been revised to reflect JFD 3 consistent with the Catawba STS markup and the Bases markup. O 1 I mc3_cr_3.6 3.6-30 March 12, 1998 I l
J Spray Additive System (Atmos ric. Subatmospheric, Ice Cc xienser, and 3.6 CONTA!WENT SYSTEMS 3.6.7 Sora Additive 5 tem (Atmospheric. Subatmospheric, Ice Condenser, and Dual LC0 3.6.7 T Spray Additive System shall be OPERABLE. APPLICABILITY- MODES 1. 2, 3. and 4. ACTIONS RE@ IRED ACTION COnPLETION TIME ' l [ CONDITION
.I A. Spray M ditive System A.1 Restore Spray 72 hours inoperable. Additive System to OPERABLE status.
t I B. Required Action and B.1 Be in MODE 3. 6 hours i associated Cogletion i I Time not met. AND Be in MODE 5. 84 hours l
' l i <
SURVEILLANCE REQUIREMENTS J SURVEILLANCE [ FNty0ENCY SR 3.6.7.1 Verify each spray additive manual, r 31 days operated, and automatic valve ir. he flow path that is not locked, seal , or otherwise secured in positio is '+ the correct position. (continued) WJI S 3.6-38 Rev 1. 04/07/95 j bLbt.Atk i
c-
~
Spray Additive System (A pheric,lubatmospheric.IceCondenser,and 1 I SURVEILLANCE REQUIREME S (continued) FREQUENCY [ SURVEILLANCE SR 3.6.7.2 erify spra 184 days ' is a [2568)y galadditive and s (4000] tank gal. solution volume SR 3.6 .3 Verify spray additive tank [NaOH) solution 184 days . concentration is a (30]% and s [32]% by /- weight. /'
/
R 3.6.7.4 Verif eac;. spray additive automatic valve (18] mo s in the flow path that is not locked, sealed, or otherwise secured in petition, i actuates to the correct position on an actual or simulated actuation signal.
/
SR 3.6.7.5 Verify spra additive flow [ rate) from ach
/ '
5 years solution's low path. O ..____.___._...--.
-- / - - . . - - . .
)
3.6-39 Rev 1. 04/07/95 nGuin O v r
McGuire & Catawba Improved TS Review Comunents ITS Section 3.6, Containment Systems O, 3.6.7-2 DOC A.1 CTS 4.6.4.2.b.3 ITS SR 3.6.7.3 CTS 4.6.4.2.b.3 for McGuire Unit 1 is modified to convert this surveillance into the ITS format. The modification deletes the words " Verifying the integrity of" and rearranges the other words to conform to the ITS wording for SR 3.6.7.3. This change is designated DOC A.1. This change ;s not shown in the CTS markups for McGuire Unit 2 and Catawba Units 1 and 2. Comment: Revise the McGuire Unit 2 and Catawba Units 1 and 2 CTS markups of CTS 4.6.4.2.b.3 to be consistent whh the McGuire Unit 1 CTS markup. DEC Response: The unit 2 McGuire CTS markup and the CTS markups for both Catawba Units have been corrected. l i O i 11 '~h (j mc3_cr_3.6 3.6-32 March 12, 1998
S eed a.h A S.6. ~/ l Q u . - -
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denler me sa at seest usi : ___ witate use j W'W S ..- . ' GE D E** H ** ** st 3.6 7 / ~ g At least emme per functlenet test ,_ _ -. _. : L1 TL& ^ ***E' . durimma escoeteer system i or aquel to
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ul tis 90 elestes. vueeMag , j leeresse the peuer as to mestaus pesar elautas
^^ the - - - - ^ . ernster then er to se Inf .
$ At least emme per la aseths by:
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McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems
/
3.6.7-3 JFD 3 JFD Base 2 (McGuire) JFD Bases 3 (McGuire) JFD Bases 5 (Catawba) STS 3.6.8 ACTION B and associated Bases ITS 3.6.7 ACTIONS 3TS 3.6.8 ACTION B provides the remedial actions for two hydrogen recombiners inoperable. These requirements have not been adopted in ITS 3.6.7. The justification JFD 3 states that these requirements are not applicable to this facility. Based on the STS Bases discussion for ACTION B and the inclusion of ITS 3.6.8 " Hydrogen Skimmer System" and ITS 3.6.9
" Hydrogen Ignition System" (Catawba);
- Hydrogen Mitigation System" (McGuire), it would seem that STS 3.6.8 ACTION B would be applicable for use at Catawba and McGuire. See Comment Number 3.6.8-2. Comment: Provide additional discussion and justification as to why STS 3.6.8 ACTION B is not applicable at McGuire and Catawba. See Comment Number 3.6.8-2.
DEC Response: The CTS does not provide for two inoperable hydrogen recombiners, therefore, the proposed change would be less restrictive. This less restrictive change was evaluated during the onsite O technical review and a decision was made to not pursue this relaxation for technical reasons. Since the existing license is not being changed, no additional justification is considered necessary in the ITS submittal.
- p y mc3_cr_3.6 3.6-33 March 12, 1998
McGuire & Catawba Improved TS Review Coments ITS Section 3.6, Containment Systems
'%./
3.6.8 Hydrogen Skimmer System 3.6.8-1 DOC A.1 DOC A.22 CTS 4.6.5.6.1.f ITS SR 3.6.8.3 CTS 4.6.5.6.1.f verifies that the motor operated valve in the hydrogen skimmer suction line opens automatically and the hydrogen skimmer fans receive a start permissive signal. In converting to ITS SR 3.6.8.3 changes are made to CTS 4.6.5.6.1.f to define that the permissive signalis from the Containment Pressure Control System. In McGuire Units 1 and 2 this change is designated DOC A.1; in Catawba Units 1 and 2 this change is designated AOC A.22. The DOC A.1 designation in the McGuire markup is the incorrect justification for this change; DOC A.22 is the correct justification. In both the McGuire and Catawba markups DOC A.22 writeup does not discuss CTS 4.6.5.6.1.f. Comment: Revise the McGuire CTS markup of CTS 4.6.5.6.1.f to show the change as DOC A.22. Revise DOC A.22 for both McGuire and Catawba to reference the changes made to CTS 4.6.5.6.1.f. DEC Response: The CTS markup for McGuire has been corrected. DOC A.22 has been revised to address O the change to CTS 4.6.5.6.1.f for both McGuire and Catawba. o) 'sv mc3_cr_3.6 3.6-34 March 12, 1998
4
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. S68 MutenDGEN SKINER SYSTBI *
~
d'Imi i um - . s m- rumr h g g 3,4,7 m Tue N $enta)tuneet Air Jesure anTitrdregen Skiemer Systems shall he OPERABLE. AppevraartfTY: IEEE5 1, 2.Q (a w 8'f " E #/
. . . aer-
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. ti e me.orshi. ' Air .. =-. andletpdregee Sklamer $} stem tamporable.
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least WI a o artthis the seat 6 hours - == ----- - -- == I W
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8C7/ed 8 , sueyrre e amer - 6 -,2 rurrEFE Each h*-s air - - ans Sktamer sustas shall dammastrated GPERABLE at least esce per 92 as -. wrtv - - py: [ - 84 MYg v a,er,taf.that 5 es the
. . --air. .. . ame W . es.sktemer a a. ., , .
start rst nei 9 , g after a 9 sh*5-=*'ar a =^** rg u.6.r.1 -
'ma En sautess !&
Werifytag t during air return fan operetten th the air [ - r fan damper losed ans trith the bypass
'.,3aJz aos the fan ester current t tess h er fanaseedis879i rmer
# #, $.(e.f. Q Verif that with the lydespen sklamer fem operettee and the aster i
. volve to its section llee elesed the fem aster currest is less than er equal to 21.5 amps seen the Ian speed is 3999 2 to rpm; (d. WrTryl saas vita une air .. .. run err, une operaWe I"' Ng f damper a the air esterm fan di llae to castelamrat's 1 esoportammt opens automatica11 trtth a 2 1 second delay
@udu/r-e4 e a Centstament Phase B Iselatt (5,) t signalg 3.0 // e. 'fylag that with the air vetern fan ting, the rAeck damper the air rotore fan disdnerse Itae to oestaineret's lower eseartmentisopen:/
1 'YL
.s4 3.t . r. 7 @ vert that the seter operated valve la the tyw' egon sktemer lee apens estamatically and the hydrogen shtamer fansreca.pk eb el-** P of.
astartperetssivestpe{and .
. . 5 vertfyt that =e** *h - are the retum at/ fan check deser3 M.4k c L*-O L ,_ ,
LFwnw cA 1 bir^) l rLs.s.s - seest esce ser is mentlyd, e air _ _ _ = i sestas shall he - e.u erstasLE ty earlhtag that the ymssure centrol systap/ functions trithin the metadiet limits speciti e Table 3.3-4. Item 6. P fec WI K . lAltf 1 3/4 6.Z7 Amendment me. 166 O - Pec tel I
Sp yw u.r
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g g EN'33 god - - -- mr e W Skiseeer demonstested 0,tRAALL at least enes per $2 ders en a f14 3.s.t.4 e sefi met me and
%sstart _Ia & w y,zM en 11aan1 \ W M ed a a e a n edente gr bt-~ 6we
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- b. fim desper closed
..rytag snet -- air resurs ras .-vos with me bypass dampers the faa ester 1
\ curvest is less er sessi to M asps edges fas speed is S M W fBe5 / -
M Ile b~2 @ 9eri that with the lydrogen skiemer fas operaties and the motor I volve la its section lies closed. the fas ester current is ess then er equel to 21.5 seps uhen the fan speed is 30001 SB rpag
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d f,4, W 4< rd. Werffyl that [th the air retora fan off, the spehQ deeper the pir reture fan discharge line to the tement's louer -
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epens asteentically with a le i sessed delay I 0*N after a . asut these 8 leelaties (5,) test gue);
- s. Serifyl with the air retare fan aparet . th ehe. deeper
; le the retare fan discharge line to the tunnet's louer
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,I 64 348'E @ Veri that the aster selve le the -
las apens celly and hydrogen sk fanst 64
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stat pseutosive signsk J Averifglag thatMS the fu eff, the veters air fem cig(sk
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.I fled Yarde 3.3.a ne- s. r skAM - IIIN t 3/4 6-27 Amendment ps. 148 ,
l . 6 e" ly /siI 9
Disc ssi c cf Ch;nges Section 3.6 - C:ntainment Systems ADMINISTRATIVE CHANGES V These changes, retained in ITS SR 3.6.3.76, 3.6.6.3, 3.6.3.3 and 3.6.36.4, are consistent with NUREG-1431. A.19 CTS LCOs 3.6.3 and 3.6.1.9 are being combined into ITS LC0 3.6.3," Containment Isolation Valves". The two CTS LCOs duplicate the requirements for the valves used for containment penetration flow path isolation. Since the wording of CTS LC0 3.6.1.9 is repeated in the Action, it is eliminated. Minor wording modifications are made in combining the LCOs, but these changes do not alter the technical requirements. This change is considered administrative and is consistent with NUREG-1431. A.20 Not used. CTS 3.5.1.9 ?,ctica c require; inoperabh v;hc; be rc;tcred ic OPERf3LE ;tatu; within 24 hour;. ITS 3.5.3 ?,ction E require; the ::=0 vahc; to be i;0hted by u;c Of at ka:t one c!c;cd and de activated automatic v he, cic;cd =;nu;' v;he, or b'ind fhngc. I;0hting a containment penctration vahe en;urc; the v;he i; perf0rming it; ;;fcty function and i; :n apprcpriate c;= pen;;tery action. Tht; change i; con;idered an admini;trative p change and h con: htent with NUREC I431. t A.21 Not used. A.22 CTS 4.6.2.c.3 and 4.6.5.6.2 require that system functions in response to the Containment Pressure Control System 'CPCS) be verified. CTS 4.6.5.6.1.f refers to a required start permissive signal for hydrogen skimers but does not state the source. ITS 3.6.6, 3.6.8, and 3.6.11 surveillance requirements provide the specific requirements to be verified and refer to the start permissive and terminate signals of the CPCS. The setpoints are already specified in CTS 3.3.2 and retained in ITS 3.3.2. This change does not alter any surveillance requirements and is therefore considered an administrative change. A.23 Not used. A.24 CTS LC0 3.6.1.8 Action b allows the ventilation system heaters to be inoperable up to 7 days and allows continued operation of the system provided a report is made to the NRC within 30 days. The report is required to state the reason for the inoperability and the planned actions to return the heaters to operable status. ]g This allowance is reformatted and retained as ITS 3.6.10 Action B. McGuire Units 1 and 2 Page A - 67 Supplement 25/20/97l
Discussign of Changes S:cticn 3.6 - C:ntainment Systems ADMINISTRATIVE CHANGES L This Action specifies that with the heaters inoperable, the heaters must be restored to operable status within 7 days or action initiated in accordance with ITS 5.6.6. ITS 5.6.6 requires the submittal of a written report containing the reason for the inoperability of the heaters and the planned corrective actions. No technical changes are made and this change is considered administrative. A.25 Not used. A.26 CTS LC0 3.6.1.8 Surveillance Requirements require the testing of ventilation filters in accordance with Regulatory Guides and ASTM codes. These detail requirements have been moved to the Administrative Controls, ITS Chapter 5.0. A new surveillance is added to CTS 3.6.1.8 and retained as ITS SR 3.6.10.2 to require testing in accordance with the Ventilation Filter Testing Program as described in Chapter 5.0. This change is considered administrative. Any technical changes to these requirements are discussed in the Discussion of Changes for Section 5.0. The change is consistent with NUREG-1431. A.27 A Note is added to CTS 3.6.5.3 which permits separate condition entry for each ice condenser door. This change is necessary to provide explicit instructions for proper application of the ACTIONS for Technical Specification compliance. In conjunction with ITS 1.3, " Completion Times," this Note provides direction consistent with the intent of the existing ACTIONS for inoperable ice condenser door and is therefore, considered administrative. This change, retained in ITS 3.6.13, is consistent with NUREG-1431. l A.28 CTS 4.6.5.3.1.a requires continuously monitoring inlet door positions. ITS SR 3.6.13.1 provides explicit instructions of "every 12 hours." Continuous monitoring of inlet door position is accomplished by the Inlet Door Position Monitoring System, CTS l 3.6.5.4. This specification, however, is relocated from the TS as discussed in R.2. The requirement of 12 hours is established consistent with the monitoring of ice bed temperature since temperature is the concern with an open door. Providing clarification by giving an explicit frequency for the surveillance is considered administrative. This change is consistent with n(_,.
) NUREG-1431. j McGuire Units 1 and 2 Page A - 77 Supplement 25/20/97l
i
-l l
McGuire & Catawba Improved TS Review Comments l ITS Section 3.6, Containment Systems I .O 3.0.8-2 JFD 3 JFD Bases 3 JFD Bases 4 (McGuire) ' STS 3.6.9 ACTION B and Associated Bases ITS 3.6.8 ACTIONS i STS 3.6.9 ACTION B provides the remedial actions for two Hydrogen Skimmer Systems inoperable. The discussion in Comment Number 3.6.7-3 also applies here only the ITSs involved are ITS 3.6.7 " Hydrogen Recombiners" and ITS 3.6.9. Comment: See Comment Number 3.6.7-3. I DEC Response: The CTS does not provide for two inoperable hydrogen skimmers, therefore, the proposed change would be less restrictive. This less restrictive change was evaluated during the onsite technical review and a decision was made to not pursue this relaxation for technical reasons. Since the existing license is not being changed, no additional justification is considered necessary in the iTS submittal. O c3 .c3.c,3.e s.e.se h.,ch 12. 1,,e
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems o 3.6.9 Hydrogen Mitigation System (McGuire only) 3.6.9-1 DOC M.8 (Catawba) CTS 3.6.4.3 ACTIONS ITS 3.6.9 ACTION C CTS 3.6.4.3 ACTIONS provide the remedial rneasures to be taken for one train of the Hydrogen Mitigation System inoperable. If these remedial measures cannot be satisfied, CTS 3.0.3 must be entered which requires action within 1 hour or shutdown to MODE 3 in the following 6 hours. ITS 3.6.3 requires that if the same remedial measures (RA A.1 and RA A.2) cannot be met the plant must be placed in MODE 3 within 6 hours. This same type of change in Catawba was characterized as a More Restrictive (M.8) change which was found acceptable. Comment: Revise the McGuire CTS rnarkup to show the change as More Restrictive and provide the appropriate Justification and discussion. DEC Response: The McGuire CTS markup has been revised and DOC M.8 from Catawba was added to the McGuire discussion of changes. O
)
i l o I () mc3_cr_3.6 3.6-36 March 12, 1998
L l-it (Q,, IbV1 So b. f I. : @- 3,4 QWITAltBElli $YSTIBIS [/4MsvM) V aff"*4 us. - un i m a _ . , >-a-y,g ,
$YSTDI d'IRTTJkr. Cole 1T1811 FOR OPElimnr
/.co 3,4,,$ STED Both trains of the -1 _
; ; i ----- -
1811 he GrotAstE. AnPLICASILITY: 8000E51 and 2. ACI.lE #NS one train of tow - - i :- .a= -y- inoperable, restore the @ ' MIsa/ A
- l 1e_ system to 3AsLE_ states within 7 days. gor secro b e the j erve llance inte a e; '
- ---- - -- + - w aanrury says on the "#
Aty.,,g A.2. OPERABLE train ~-a aZ:7- __
----__-~
8V5fft T" 17,b ) SURVEftf M r Rfouintm.nis - CE'Oh Each train of the 6 11 be desenstrated OPERAsLE: g7,y4 gpg g,,g e'A 5 A 'I . / g > At least once per 92 da y one izingGBJsupplybreakersand verifylg33RR a st piten are enerytted,# and
$4 5. C, . f . 3 & At least once pe verify (gZS temperature of each igniter is a minimum of 1700*F.
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- w d c o h cars /s o. c f .I N IA7 , . . _ ignig ;_ m y - q ; ---
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neautaE - leiti 1 3/4 6-19 Amendment M. 166 O y ia
I
. Specification 3.6.9
~
INSERT 12.b B. One containment B.1 Restore one hydrogen 7 days region with no ignitor in the affe:ted OPERABLE hydrogen containment region to f ignitor. OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated. . Completion Time not > met. O 9 9 *
-f McGuire Page 7 of 2_
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- - - - - ---- Insperable, restore t[he3* C T' O 4cTeos/ A-litilth ese .,,t ershie trela ofte th'etusa t .iths. 7 rsi.e =-- -
, iuance is s al of- .1----- --a.--- *M7 days se the rug AW/a# 4f. o,,ptRABLE trein -i r== ;- - k n -. is : : . : - --- . t 84S6fti 12.6s) er, , _ zm f
a;s arS Each trois of the - -- mC-. ir- ,shall be demonstrated OPEMBLEs //h s casu,,9 g At least esce per M energirfag W breakers and A. S_t A.(,'V. / verifyt m at 1 piters are medfand if 3 4.4_3 g At least esce per verifytg]Eh temperature of each Ipiter is a elatans of 1 . 1 k> h a lautenL heI;7;7r) . 1 r (a5 owats auAe w4twu@ 0 g ,,, _. , n __ n ,s,o SA 8.6.4.z. w-pears'.sytters, *_ _ _ regles. lecAWillE a glitT 2 3/4 6 19 Amendment No. 144 x
/afe. //'Z. J i
O .- Specification 3.6.T b' ~ INSERT 12b B. One containment B.1 Restore on hydrogen 7 days region with no ignitor in the affected L,23 0PERABLE hydrogen containment region to l ignitor. OPERABLE status. C. Required Action C.1 Be in MODE 3. 6 hours and associated , Completion Time OM.8 not met.
- e O ce i.. e ee z <2-
Discussicn cf Ch:nges Section 3.6 - C;ntainment Systems TECHNICAL CHANGES - MORE RESTRICTIVE M.5 Not used. M.6 Not used. M.7 An additional surveillance is proposed for CTS 3.6.1.7 to verify ~ each door in each access opening to the reactor building is closed, except when the access opening is being used for normal transit entry and exit. This additional surveillance is acceptable because the integrity of the reactor building is importe.nt to the dose calculations following a DBA and it is required by CTS 1.27.a. This change is considered more restrictive because it requires additional surveillance beyond that which are presently performed for the reactor building integrity. This change, retained in ITS 3.6.16, is consistent with NUREG-1431. M.8 CTS 3.6.4.3 Actions provide actions for inoperable hydrogen igniters. If these actions can not be satisfied, CTS LCO 3.0.3 must be entered which requires action within 1 hour or a shutdown to MODE 3 in the following 6 hours. ITS 3.6.9 requires that if m these some actions cannot be met the plant must be placed in MODE U 3 within 6 hours. This change is slightly more restrictive since the CTS would provide 1 additional hour. This change is acceptable because it places the plant in a MODE where the i specification is not applicable. This change is consistent with l NUREG-1431. %t =cd. l l M.9 CTS 4.6.5.3.2.a requires verifying that the intermediate deck \ doors are free of frost occumulatton. ITS SR 3.6.13.2 requires l verifying that the doors are not impaired by ice, frost, or debris. This requirement is more restrictive than the current stated requirements, however, it is consistent with existing operating practices and with NUREG-1431. O 1 McGuire Units 1 and 2 Page M - 22 Supplement 25/20/97l I
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.10 Annulus VentRation System (AVS) 3.6.10-1 DOC A.1 i DOC A.5 (Section 1.0) CTS 1.27 ITS 3.6.10 CTS 1.27 provides the definition for Reactor Building integrity, and is justified by DOC A.5 as deleted on the CTS markup of ITS 1.0. This !s incorrect. The definition is part of the l technical specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.27 should be included in the CTS markup of ITS 3.6.10. CTS 1.27.a and 1.27.c become part of ITS 3.6.1.6 and is considered an Administrative change (DOC A.1). (See Comment Numbers 3.6.16-1 and 3.6.16-2). CTS 1.27.b becomes ITS LCO 3.6.10 and is an Administrative change (DOC A.1). Comment: Revise the CTS markup of ITS 3.6.10 to include an appropriate markup of CTS 1.27 and provide any additional discussion and justification for these Administrative changes. See Comment Numbers 3.6.16-1 and 3.6.16-2. DEC Response: A markup of CTS 1.27 item b was added to the CTS markup for ITS 3.6.10 reflecting the inclusion of this part of the definition within the LCO statement as DOC A.1. O l O ca c
>.e - e.e-s7 hsrch 12. 1eee
SeedJk,3.(,.a hEFINITIONS [ PROCESS CONTROL PROGRAM (PC O 1.23 The PROCESS CONTROL ROGRAM (PCP) shall contain the current formulas, sampling, analyses, test and determinations to be made to ensure that process ing and packaging of so id radioactive wastes based on demonstrated processin of actual or simulate wet solid wastes will be accomplished in such a way a to assure compliance ith 10 CFR Parts 20, 61, and 71, State regulations, burial ground requi nts, and other requirements governing the disposal f solid radioactive ste. PURGE - PURGING 1.24 PURGE or RGING shall be the controlled process of dischargin air or
$t t. gf ( gas from a co finement to maintain temperature, pressure, humidity, oncentra-Q, m g,o / tion or othe operatin condition, in such a manner that replaceae air or gas is requ red to pur fy the confinement.
OUADRANT OWER TILT RATIO 1.25 ADRANT POWER TILT RATIO shall be the ratio of the max um upper excore dete or calibrated output to the average of the upper excor detector cali-bra d outputs, or the ratio of the maximum lower excore de ctor calibrated ou ut to the average of the lower excore detector calibra ed outputs, which-e er is greater. With one excore detector inoperable, t remaining iree detectors shall be used for computing the average RATED THERMAL POWER f 1.26 RATED THERMAL POWER shall be a total core hea transfer rate to the
> reac_ tor _ coolant of 3411 MWt.
REACTOR BUILDING INTEGRITY 1.27 REACTOR BUILDING INTEGRITY shall exist when: b 4f \ Y Each door each access openin is closed xcept when the access opening s being used for norma transit ntry and exit, then at f, t15 %.lt.jk least ne door shall be clated-WCW'O The Annulus Ventilation System is in compliance with the requirements CAl s 8 w'S .4 l' of Specification 3.6.1.8, and
*N c. ThesealiD/mer.hanismassociatedwitheachpen ration (e.g., welds, Se m1.t.A bellowsfor 0-rings) is OPERABLE.
I REACTOR TRIP SYSTEM RfdPONSE TIME b0 0\ 1.28 The REACTOR IP SYSTEM RESPONSE TIME shall be the time terval from be ITS l o / when the monitor parameter exceeds its Trip Setpoint at th channel sensor until loss of ationary cripper coil voltage. ] McGUIRE - UNIT 1 1-5 Amendment No. 166 O l p ,. 4 Al l
5'reaMt., SLlo
/NffMITIONS /
HKE55 CONTROL PROGRAM (PCP O 1.23 The PROCESS CONTRO R0 GRAM (PCP) shall contain the current fonsulas, sampling, analyses, tese, and determinations to be made to ensure that process-ing and packaging of s id radioactive wastes based on demonstrated processing of actual or simulat wet solid wastes will be accomplished in such a way as to assure complianc with 10 CFR Parts 20, 61, and 71. State regulations, burial ground req resents, and other requirements governing the disposal of solid radioactiv waste. PURGE - PURG1 gee 4f 1.24 PURG or PURGING shall be the controlled process of discharging ir or gas from confinement to maintain temperature, pressure, humidity, ncentra-Or(1110 tion or ther operating condition, in such a manner that replaceae air or gas is quired to purify the confinement. 00 T POWER TILT RATIO t 1.25 QUADRANT POWER TILT RATIO shall be the ratio of the ximum upper excore - detector calibrated output to the average of the upper e ore detector cali-brated outputs, or the ratio of the maximum lower excor detector calibrated output to the average of the lower excore detector ce brated outputs, which-ever is greater. With one excore detector inoperabl , the remaining three detectors shall be used for computing the av age. RATED THERMAL POWER 1.26 RATED THERMAL POWER sha11 be a total core heat transfer rate to the reactor coolant of 3411 MWt. - REACTOR BUILDING INTEGRITY O 1.27 REACTOR BUILDING INTEGRITY shall exist when:
/
g a. T.acn coo each access opening is closed e ptwhentheaccess]
<gn,%g,cc u,w openin being used for normal transit en and exit, then at j
least e door shall be closed,
# The Annulus Ventilation System is in compliance with the requirenents
'C^ 3
- of Specification 3.6.1.8, and
( 3m,9p p. 6, 7,= bel 1[9.:5 or
. u.t..l-0-rings).mcTated with/ each penetration (e.g., wel is OPERA 8LE. .
~
("IfEACTORTRIPSYSTEMRESPONSETIME 1.28 The CTOR TRIP SYSTEM RES SE TIME shall be the time interval f
/g %, when the nitored parameter ex eds its Trip Setpoint at the channel nsor
( g g ,y ,, untti ss of stationary gri r coil voltage. McGUIRE - UNIT 2 1-5 Amendment No. 148 b
1 i McGuire & Catawba Improved TS Review Comments 1 ITS Section 3.6, Containment Systems O 3.6.10-4 JFD 9 JFD Bases 5 CTS 4.6.1.8.b.3 STS SR 3.6.13.5 and Associated Bases CTS 4.6.1.8.b.3 vorifies each AVS train flow rate is 8000 cfm
- 10% during system operation.
STS SR 3.6.13.5 performs this same surveillance. ITS 3.6.10 does not include STS SR 3.6.13.5 based on the justification (JFD 9) that the flow test is covered by ITS SR 3.6.10.2. ITS SR 3.6.14.2 only tests the filter trains, it does not test the system as a whole. The staff finds the deletion of STS SR 3.6.13.5 from the ITS as unacceptable, and is considered as a generic change which is beyond the scope of review for this conversion. Comment: Delete this generic change. DEC Comment-l The iTS submittal has been revised to conform to the STS. O (oj mc3_cr_3.6 3.6-40 March 12, 1998
o- ,. I AVS 3.6.10 SURVEILLANCE REQUIREMENTS' SURVEILLANCE FREQUENCY. SR 3.6.10.1 Operate each AVS train for a 10 continuous 31 days hours with heaters operating. SR '3.6.10.2 Perform required AVS filter testing in In accordance accordance with the Ventilation Filter with the VFTP TestingProgram(VFTP). SR 3.6.10.3 Verify each AVS train actuates on an actual 18 months or simulated actuation signal. SR 3.6.10.4 Verify each AVS filter cooling bypass valve 18 months can be opened. O y- -- bS 3.h. ID. 7 VeNi (Ad ' AVS Mtn hog rak w 2 ~7 2.00 ct~ SA i 8700cfr. LO:
'McGuire. Unit 1 3.6-26 Sv/phwY L M i
AVS 3.6.10 O V' SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.10.1 Operate each AVS train for 210 continuous 31 days hours with heaters operating. SR 3.6.10.2 Perfonn required AVS filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP). SR 3.6.10.3 Verify each AVS train actuates on an actual 18 months or simulated actuation signal. SR 3.6.10.4 Verify each AVS filter cooling bypass valve 18 months can be opened. O - S[L 3. b. lo. 3- Ve ' h e d A W N ia h6v) rak (g g L r 7too#m me .5 fgx tCs. McGuire Unit 2 3.6-26 ##/NLM ;
]
l
)
AVS B 3.6.10 b' V BASES , i SURVEILLANCE SR 3.6.10.2 REQUIREMENTS (continued) This SR verifies that the required AVS filter testing is perfonned in accordance with the Ventilation Filter Testing Program (VFTP). The AVS filter tests are in accordance with f Regulatory Guide 1.52 (Ref. 5) with exceptions as noted in the UFSAR. The VFTP includes testing HEPA filter perfonnance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional infonnation are discussed in detail in the VFTP. SR 3.6.10.3 The automatic startup on a Containment Phase B Isolation signal ensures that each AVS train responds properly. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. [3
\
Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. Furthermore, the SR interval was developed considering that the AVS equipment OPERABILITY is demonstrated at a 31 day Frequency by SR 3.6.10.1. SR 3.6.10.4 The AVS filter cooling electric motor-operated bypass valves are tested to verify OPERABILITY. The valves are normally closed and may need to be opened to initiate miniflow cooling through a filter unit that has been shutdown following a DBA LOCA. Miniflow cooling may be necessary to limit temperature increase in the idle filter train due to decay heat from captured fission products. The 18 month Frequency is considered to be acceptable based on valve reliability and design, and the fact that operating experience has shown that the valves usually pass the ! Surveillance when performed at the 18 month Frequency. I i z ) i n) (continued) , McGuire Unit 1 B 3.6-66 54/64L. 6/09/97L-
INSERT O SR 3'.6.10.5 The proper functioning of the fans, dampers, filters, adsorbers, etc.,
- as a system is verified by the ability of each train to produce the' - required system flow rate. The 18 month Frequency is consistent with Regulatory Guide 1.52 (Ref. 5) guidance for functional- testing.
O O
AVS B 3.6.10-O BASES SURVEILLANCE SR 3.6.10.2 REQUIREMENTS (continued) This SR verifies that the required AVS filter testing is perfonned in accordance with the Ventilation Filter Testing Program (VFTP). The AVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5)' with exceptions as noted in the UFSAR. The VFTP includes testing HEPA filter perfonnance, charcoal adsorber efficiency,' minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP. SR 3.6.10.3 The automatic startup on a Containment Phase B Isolation signal ensures that each AVS train responds properly. The 18 month Frequency is based on the need to perfonn this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were perfonned with the reactor at power. O Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. Furthermore, the SR interval was developed considering that the AVS equipment OPERA 8ILITY is demonstrated at a 31 day Frequency by SR 3.6.10.1. SR 3.6.10.4 The AVS filter cooling electric motor-operated bypass valves are tested to verify OPERABILITY. The valves are normally closed and may need to be opened to initiate miniflow cooling through a filter unit that has been shutdown following a DBA LOCA. Miniflow cooling may be necessary to lidt temperature increase in the idle filter train due to decay heat from captured fission products The 18 month Frequency is considered to be acceptable based on valve reliability and design, and the fact that operating experience has shown that the valves usually pass the Surveillance when perfonned at the 18 month Frequency. t (continued) McGuire Unit 2- 8 3.6-66 Ew(emFL 5/?0/97 t
INSERT-SR 3.6.10.5 The proper functioning of the fans, dampers, filters, adsorbers, etc.,
..as a system is verified by the ability of each train to produce the required system flow rate. The 18 month Frequency is consistent with Regulatory Guide 1.52 (Ref. 5) guidance for functional testing.
1 4 O l (g
6peCihcaltN ?.4JO O' 7.G
- CONTAllsetT SYSTEMS 33,g AIERILil5 VGITILATION SYSTDI (N.5)
~
i ctfumsg ramaa ff6ii FOR Opr1FattasT tc o 3.6hwe 8--- m - - las veaunauem 3rsMshall be OPDtABLE. APPLICABILITY: H00ES 1, 2, 3, and 4 ~) b5IT M5)
\ .
,, . gm ACM/M $ With nae '- -lus Ventilation Systen inamerable reasonsAfher9
>?Wpre-heaters testes,4a 4.6.:A s and .1.sM M restere gg the taoperable system to GPERA5LE s'.ases witale T days er be in at
~
least fl0T stale 8Y within the next 6 hours and in COLD $4EIT00lel withis the following 30 hours. g*g 6. With the -aeasers tested la 4 .1.8.4 and 4.6.1.8.d. esperable, reste i rable pre de rs to OPDIABLE sta thia 7 days or f a Spect I rt in cordance with Specif tien 6.g.2
, /3 wi a 30 days spect i m ason for inoper ity and the anned acti ds to re the pre-h:ters to **' r stagne ,
(f tilaffaa sveda tha1Fie deadastradhd appans y,; E.6. $. l @ At least once per_31 days C'TaGefED>t1"I k ' I ing svuuvy. - msw --__..', ism "t .. reos rs andder1f as that the sys me opere<As for as iesst ag L4,/3
. 2/, 'with the pre aters operating; -
_ j
/N b. structural malatenance i At en least oncefl Ner er charcoalr 18 sooths, the IIEPA r6er housor ogs
) after er (2) followfag I fire, or chemical release la any vestiIatten zone communi-O paintingIththesystes,by:
cattag w
- 1) Verifyf that the ventilatten systes satisfies tee in lace tre on and bypass leakage testing cri a of I SN M88d / dance of Re thanC.S.a.
posittens 14 and uses C.5.c andthe testofprocedure atory Guide C.S.d 5Z. 1.gulatory j75 g'fj llevision 2, March Ig78, and the system ou rate is 8000 cfm a 10%;
- 2) Verifying within 31 days after removal that a laboratory anal-ysis of a representative cartes sample obtataed la accordance with itegulate Position C.6.b of late Emide 1.52. Revi-sien 2 March g78, and tested per TM
. -8g has a methyl A indide menetration of less than 44 and j
$y{,(,,10.7 kfh Verifylag a system flew rate of 8000 cfm a 10% durieseratio
~ ~ _ - _ ___,y- __2
/ -
- A ene-t change is granted in and 4 to allow repair vities for the inment purge supply and/ zhaust isolation valves the upper and
/),/ 1 compartseat that were a Modes 3 and 4 followi steam generator
( lacement estage. McGil!ItE - INIIT 1 3/4 6-11 Amendment No.174 e /Ob O . l
SWE6tbn
/ 3.6s/0
- r,h CONTAlflMENT SYSTEMS
=
y /OAfgeN.1f5 VENTil.ATION SYSTEM [A/S) o.i 3 _. - m c-cm.n
. / C o 3.6 C _M
'MAnnetrus va=Ma#a= 14+Ma11 be OputABLE. I APPLICABILITY: MODES 1, 2, 3, and 4 ,
(ACftwnD 1
, gIgt A@f l
- I
$ litth_one Annulus ventilatten,5ystem,faoperabl r dhah tWpre-=ter$Asw m == 1 == === .5 1 .d- tore i I
thelnepersale systes to uresA8LE states withia 7 days or be la at AcffmC. e least HDT STAlWSY within the next 6 hours and la COLD Sist!Dolet within the following 30 hours.
- b. titth pre-heaters ted in 4.6.1. a and 4.6.1.8.d inoperabi ,
g res the inspe pre-heaters OPGtABLE states thia 7 , or i e a Special rt is ^^-:--f :e with Speciff ion 6.g.2
/3 wi la 30 days ytag the for inoperabi ty and anned action return the ters to status suavEftuustE REQUIREMEwf5
~
MS Each Asa61us vaatuatMa sw<ta= aM11 he '-- Ma+ d ed= rd W:7.6/0,/ a. At least once per 31 day : & sr" 2di navn*=
^
une
^
^ .3 4w Y _' ' = =ea 2f and pc.rl y
,a rifying 1 hat the system operates per at least,10 4A-A . .~ld hears wisa pre-heaters operstlesa.
M . ast once per 18 months, or (1) after any structural asiatenance en the HEPA filter er charcoal adsorter housings or (2) following fire, or chemical nicase la any vestlIsties zone communi. O palattagIththesystem,by: cattog w
- 1) Verifying that the ventilatten system satisffes the in-place penetraties and bypass leakage testing accercance criteria of less than 1% and uses the test precedure gridance of flegulatory gg positions C.5.a. C.S.c and C.5.d of fleguirtory Guide 1.5Z, l Revisten 2, March Ig78, and the system flam rate is 8000 cfm i of / 756. , 10%'s
- 2) Verifying within 31 days after removal that a laboratory anal-ysis of a mpresentative carben sample obtained la accet11ance
- with Regulatory positten C.6.6 of Regulatory Guide 1.52. Reef.
k . sten 2. March ledide Ig78,ofand penetretten lesstested than 4%; per and ASTM D3403-8g has a settg1
$(i M.t% 5' 3) Verifying a system flew rate of 8000 cfs a 10% during system raties when tested la accorfance with AltS! 11510-1g75.
-u n-__ny _ m y p j i *A time change is g ted la Modes 3 4 to allow repair lytties for l g,/ alament pu upply and/or e t isolation valves r the upper and
! r cespartseat t were open la 3 and 4 following steam generator lacement estag Mcef!RE - Ull!T 2 3/4 6-11 Amendment Ilo.156 O pp lof 3
l
. M4 0 - - -. w
. a 3.6.g
& u r $URVEILtANT EQUIREENTS (continued)
SURVEILLANCE FREQUENCY SR Verif in .e 3.6g.3 .ctoJeach., 34.oi.t.o .ct n .4.t..uates i. 1.181 months on .n
~-
con elsk onthe ~, @ LH 3.sZ4 v.ritychRme.r 2 7 ) (sR3..67v.g,,ledt,.4nn,.t.<5* o; N rr. e f4.r r# EP J G N,L 9
\
" "5- 3.6-50 Rev 1. 04/07/95
&kwsc O
l
L.- ,
],
l 3 .- O. @ CIENI m.i am ir, . --- i e 83.6.g 9.
=ASES _ m 5e) oa coa,la.;,~-t-
$URWEILLANCE SR 3.6'.S.3 A*H 8 J'**/* M" h.
IEQUIRDefiS A5'9 " * '
..(continued) Theautomaticstartup(ensuresthateach properly. TheS8EmonthFrequencyisbasedontheneedtotrain responds h perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating esperience has shown that these comp the 38k(onents usually pass month Frequency. the Surwillance Therefore tie Frequencywhen was perfonned at concluded to be acceptable from a reliability standpoint.
Furthennore, the SR interval was developed considering that
-th Ee equipment OPERABILITY is demonstrated at a 31 day Frequency by SR 3.6. .1.
- . h/mey s/irt/de. ,nalen,- oje,mk O 9 n..~:%
fQ e/,se/ e/ /c sorr.de. h ite
~
~
ss .- - HEY,TaEh tEfi1*meC TheK18)-month F m e=n ed to verify a
"d'-1 4{ ) C isandconsidered to be acceptable based on w rel p,u.nydeudsJel
,,,,, w (sumn des 4 - enn. _ .... . _ .. _ _
and the fact that operating esperience has
........,of @
O Mw6%i>64. t.ea, ,,,,gy c 4, nee qg
.e s..,:
,e
~
the N usually pass the Surveillance when 7erformed at the 08kmonth Frequency.
)6)
~
1 *np98rense en,s], - A g yf(kap I 3.6. 5 uret.h % / A 4 I***'thd4 cpm , The r functi ing of the fans, deepers, fi s. 6El m Pr M S. a ,etc. as a systes is verified b t ability of each train to the reeuirelenw-+= 51 rate. The
, M18$.monthF ama = = .r m y a m Dis consistent '
with Regula y Guide 1.52 (Ref.( )guidendeforfunctionaJ l I testing. _
/
REFERDICES 1. 10dR50,AppendixA.ElC41.
- 2. @ SAR, Section d
^
- 3. @SAR, Chapter 115F. [80 "E U M7"kIf
- h. Regulatory Guide 1.52. Revision .
idBNTS- B 3.6-145 Rev 1. 04/07/95 NC&o . b m
SfCC/$/Cabo .S~S // mc/aded N \ t : tmert.Dc / _. O 4 CONTAINMENT SYSTEMS AfgIULUS VENTILATION SYSTEM LIMITIIIG COMITION FOR OPERATION 3.6.1.8 Tuo independent Annulus Ventilation Systems shall be OPERABLE. (
; APPLICA8!LITV MODES 1, 2, 3 and 4.*
, k KIEE:
gegph a. litta one Amaulus Ventilation System inoperable for reasons other than the pre-heaters tested la 4.6.1.8.a.Jpd 4.6.1.8.d.5, restore d M S*4 the inoperable system to OPERA 8LE status withia 7 days or be la at least HDT STAm8T within the next 6 hours and la COLD Set,*TDOWI withis the following 30 hours.
- 6. tilth the pre-heaters tested la 4.6.1.8.a and 4.6.1.8.d.5 feoperable, restore the inoperable pre-heaters to OPERABLE status within 7 days, or file a Special Report in acconlance with Specification 6.g.2 within 30 days specifylag the reases for inoperability and the planned actions to return the pre-heaters to OPERABLE states.
~'
SURVEILLANCE REOUTREMENTS 4.6.1.8 Each Anacles Ventilation Systen shall be demonstrated OPERABLE:
- a. At least esce per 31 days on a STAGG0tED TEST SASIS, by initiating.
from the centrol room, flow through the NEPA filters and charcoat adsorbers and verif ag that the system operates for at least 10 hours'with the pre ate's' r eperattag;
- 6. as eess r Is , or (1 any strw^ 'ai esta
/ A./ the i ter er reoal adse) er housings (2) foil
' cal release a any wenttI fee rene palating, fre, or cating th the s , by: f-)'
,/ %h Af Verifying that the ventilation system satisfies the la-place penetrattoa and bypass leakage testing acceptance criteria of I less than 1% and uses the test procedme guidance ofW~
l (Fiwt a- i .1.. . c.s:c an64.kf eDRegulatory Guide 1.$2, Rev s' on 2, March 1975, and the system flow rate is 8000 cfm a 10%;
,/ C. VerifMwithM 31 daet afteF =dFraB that a laboratory anal .
ysis of a_ representative cartes sample obtained la accordance with ' m e - - = = latory Guide 1.52. Revi-Sel arW
- sten D rch Ig78, and tested per TM 03803-8g has a methyl 6e IT11A.r" iodide penetration of less than 4%; and
- 3) V ying a s flow rate 8000 cfm a 1 ring systen ration tested la a e with 11510-1975. J j i
- A ene-time change is granted in Modes 3 and 4 to allow repair activities for
)
s,e sdety the l'"" containment suppiy and/or exhaust isoiation vaives for the opper and
,ugt WeM ' Pen in Modes 3 and 4 foHowing the steam of /r3 S.4, 1 **"P'""'"t t replacement estaee.
.. McGU1RE - ist!T 1 3/4 6-11 Amendment No.174 O
pye .57sF69 J
r SftbhCa.Wt n
' ** r. f. //
h hck/edm
/A58 M k CONTA18 MENT STSTDtS ..
,, Af5 RADS VENTILATION STSTEM LINITilIG ColeIT10N FOR OPERAT10N 3.6.1.8 Two independent Annulus Ventilatten Systems shall be OPERABLE.
APPLICA81LITY: MODES 1, 2, 3, and 4.*
-: EllEl!
- a. With one Annulus Ventilation System inoperable for reasons other than the pre-heaters tested la 4.6.1.8.j a 4.6.1.8.d.5, restore fee the inoperable system to OPERA 8LE status eithia 7 days or be la at f least NOT STAfGST within the next 6 hours and la COLD SHUTD0681 Ot' /U 3 6 e
within the following 30 hours, b, With the pre-heaters tested la 4.6.1.8.a and 4.6.1.8.d.5 faeperable, restore the inoperable pre-heaters to OPERABLE status withia 7 days, or file a Special Report in accor11ance with Specification 6.g.2 within 30 days specifying the reason for inoperability and the l planned actions to return the pre 4 eaters to OPERA 8LE status. SURVEILLANCE REOUIREMDITS
. N 4.6.1.8 Each Annulus Ventilatten System shall be demonstrated OPERABLE:
- a. At least once per 31 days en a STAGGERED TEST SASIS, by initiating, free the control room, flew through the HEpA filters and charcoal.
adsorbers and' verifying that the system operates for at least 10 hrs with the pre 4 eaters eseratines
- b. At le suce per a montas, or (1 after asqy strue ral salaten en HEPA fil er charesel housings. (2) fell M
O. ating fire r chemical re ase la any vest ties zone t- j I tingwIth system, by: l that the ventilatten systes satisfies the fa-place OA.) b ,b g Verifyt - penetraNos and bypass leakage testing acceptance criteria of less than 1% and uses the test orecedure guidance ofGaEQHE5b Iderfttsat ur.'aA.5MaDRegulatory Guide 1.52, Revisten 2, March 1978, and the system flow rate is 8000 cfm a 10%;
- c. Verifyf V witM E 3AiysAftaz#emsfaUthat a laboratory anal-ysis of a reer <enE - - *a= sample obtained is accordance d *# with3aguratopf6sitteert,531pRegulatory Guide 1.52, Revi-
. sten z, nartn zws, ana testes per ASTM D3803-8g has a methyl Su m.44 iodide penetration of less *= 4%: and j b IT5W'
- 3) Verifying a tem flow rate 8000 cfm a 10% durine' system operatten tested la edance with AflSI 11510-)975. j) i
- A ene-time change is granted in P!es 3 and 4 to allow repair activities f 9c M#/ the conta(anent purye supply and/ exhaust isolation valves for the upper and '
g j 7=; .g, 4 lower cespartment that were open in Modes 3 and 4 following the steam generatorj replacement outage.
. . - McGUIRE illlli 2 3/4 6-11 Amendment No.156 i
O g nav
Justificcticn f r Devictions SIctitn 3.6 - Refu211ng Operations TECHNICAL SPECIFICATIONS NOTE: The first five justifications for these changes from NUREG-1431 were generically used throughout the individual LC0 section markups. Not all generic justifications are used in each section.
- 1. The brackets have been removed and the proper plant specific information or value has been provided.
- 2. Editorial change for clarity or for consistency with the Improved Technical Specifications (ITS) Writer's Guide.
- 3. The requirement / statement has been deleted since it is not applicable to this facility. The following requirements have been renumbered, where applicable, to reflect this deletion.
- 4. Changeshavebeenmade(additions, deletions,and/orchangestotheNUREG) to reflect the facility specific nomenclature, number, reference, system description, or analysis description.
- 5. This change reflects the current licensing basis / technical specifications.
(0,) 1
- 6. Changes were made throughout ITS 3.6 to incorporate the use of the Containment Leakage Rate Testing (CLRT) program which will include the requirements of 10 CFR 50 Appendix J. The changes are consistent with generic change TSTF-52 to NUREG-1431 provided to NRC by the industry owners groups, except that the station uses option B for type A testing, and option A for types B and C testing.
- 7. NUREG SR 3.6.9.2 has been replaced with ITS SR 3.6.8.2 that measures the hydrogen skimmer fan motor current while flow through the system is blocked. It provides adequate information to ensure the system flow is not degraded and is consistent with the current TS requirements.
- 8. Action B was added to ITS 3.6.10 to address the special heater considerations within the current TS. The heaters are not required to meet the system design bases.
- 9. NUREG SR 3.6.13.5 wn deleted bec=c it i'; covered f r. allows testing 18 months on a staggered test basis. ITS SR 3.6.10.2 which requires testing 18 months in accordance with CTS requirements and the Ventilation Filter Testing Program (VFTP). The VFTP specifies the system flowrate in ITS 5.5.11 and requires it to be verified during required RG 1.52 testing. l
%.) McGuire Units 1 and 2 la Supplement 25/20/97 l
i McGuire & Catawba Improved TS Review ftwnts-ITS Section 3.6, Containment Systems 3.6.12 Ice Bed 3.6.12-1 DOC L.26 (McGuire only) JFD 1 JFD Bases 1 CTS 4.6.5.1.b.1 ITS SR 3.6.12.5 and Associated Bases CTS 4.6.5.1.b.1 requires a chemical analyses of the stored ice to verify boron concentration and ph at least once per 9 months. The CTS markup indicates a proposed change of frequency from 9 to 18 months in conformance with the STS. DOC L.26 provides the justificatiori for the proposed change which is acceptable. The markup for corresponding ITS SR 3.G.12.5 shows the Frequency as 9 months. The Bases and " clean"ITS versions show l the Frequency to be 18 months. See Comment Number 3.6.12-2. Comment: Correct this discrepancy. See Comment Number 3.6.12-2. DEC Response: The STS markup for McGuire has been corrected consistent with the CTS markup. O l
)
1 r3 .c3_cr_3.6 s.e-41 March 12, 1998
0p . Ice Bed ora i-2
-3.6. g SURVEILLANCE REQUIREMENTS (continued)
{g - SURVEILLANCE FREQUENCY SR 3.6. 6.5 Verify by chemical analyses of at least $1N nine representative sanples of stored ice: months @
- a. Boron concentration is > *(1800( ppm; @
and
- b. pH is a (9.06.and s 19.51'.
SR 3.6. .6 Visually inspect, for detrimental 40 months structural weer, cracks corrosion, or other damage. two ice baskets from each azimuthal group of bays., See SR 3.6 .3.
)
idQG-!Pr 3.6-55 Rev 1. 04/07/95 j N S iseeNb t' N
) McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.12 2 DOC L.26 JFD 1 JFD Bases 1 i JFD Bases 3 (Catawba) CTS 4.6.5.1.b.1 ITS SR 3.6.12.5 and Associated Bases CTS 4.6.5.1.b.1 requires a chemical analyses of the stored ice to verify boron concentration and ph at least once per 9 months. The Catawba CTS markup does not change this frequency to 18 months but retains the 9 month frequency in ITS SR 3.6.10.3. The same surveillance in the McGuire iTS (SR 3.6.12.5) has a frequency of 18 months (See Comment Number 3.6.121). The justification provided in the McGuire CTS markup (DOC L.26) for the frequency change would seem to apply as well to Catawba. Comment: Provide additional discussion and Justification to show why the frequency change for CTS 4.6.5.1.b.1 only applies to McGuire and not to Catawba as well. The discussion should include any design differences or characteristics between McGuire and Catawba which would either allow the change to be implemented at Catawba, or require McGuire to retain the CTS frequency of 9 months. DEC Response:
\
[l C The ITS has been revised to add the change for Catawba for the same reasons as McGuire. _ /3 v
/ 3.6-42 March 12, 1998 mc3_cr_3.6 I
i
McGuire & Catawba Improved TS Review Comuments ITS Section 3.6, Containment Systems U 3.6.12-3 DOC LA.14 CTS 4.6.5.1.b.2 (McGuire) CTS 4.6.5.1.c (Catawba) ITS SR 3.6.12.2, SR 3.6.12.3 and Associated Bases (McGuire) ITS SR 3.6.12.4, SR 3.6.12.5 and Associated Bases (Catawba) - CTS 4.6.5.1.b.2 (McGuire) and CTS 4.6.5.1.c (Catawba) require verifying that the minimum average ice weight of a representative sample of ice baskets shall not be less than 1081 (McGuire)/1273 (Catawba) pounds per basket at a 95% level of confidence. The CTS markup indicates that "at a 95% level of confidence" was not retained in corresponding ITS SR 3.6.12.2.a and SR 3.6.12.3 for McGuire and SR 3.6.12.4.a for Catawba but instead was relocated to the Bases. However, "at a 95% level of confidence " was in fact retained in corresponding ITS SR 3.6.12.2a, and SR 3.6.12.3 for MCGuire and SR 3.6.12.4.a and SR 3.6.12.5 for Catawba. The CTS markup is in error. Comment: Revise the submittal to
- correct the CTS markup.
DEC Response: Duke Energy disagrees that the CTS markup is incorrect. CTS 4.6.5.1.b.2 (McGuire) and CTS 4.6.5.1.c (Catawba) do specifically require the weight of an additional 20 baskets be 3 determined at a 95% confidence if the representative 6 baskets contain less than the required amount. These CTS surveillances are retained in ITS SR 3.6.12.4.a. The ITS suveillance 1 only discusses representative baskets and relocates the discussion of 6 baskets and 20 baskets and the required confidence level to the Bases for ITS SR 3.6.12.4. A specific statement for the 95% confidence level is not specified in ITS 3.6.12.4.a, consistent with the i STS. ITS SR 3.6.12.4.b does specify the 95% confidence level, but this is from the discussion of totalice weight (not the representative sample) which comes from a different paragraph in the CTS surveillance. { l mc3_cr_3.6 3.6-43 March 12, 1998
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems V 3.6.12-4 DOC LA.14 CTS 4.6.5.b.1 ITS B3.6.12 Bases SR 3.6.12.5 (McGuire) ITS B3.6.12 Bases SR 3.6.12.3 (Catawba). CTS 4.6.5.b.1 requires verifying that the stored ice has a ph of 9.0 to 9.5 at 20*C "at 25' C for Catawba). The CTS markup proposes to place
- at 20' C" ("at 25'C" for Catawba) in the Bases. However, "at 20*C" ("at 25'C" for Catawba) could not be found in the Bases for ITS SR 3.6.12.5 (SR 3.6.12.3 for Catawba). Comment: Revise the Bases to include this temperature limit or provide additional discussion and Justification with regards to its deletion.
DEC Response: The Bases have been revised to include the specified temperatures. o .e,;.e s.e. .smh m. me i
Ir.e Bed B 3.6.12 i , BASES SURVEILLANCE SR 3.6.12.i (continued) REQUIREMENTS of frost or ice > 0.38 inch thick, a representative sample of 20 additional flow channels from the same bay must be visually nspected. If these additional flow channels are all found to be acceptable, the discrepant flow channel may be considered single, unique, and acceptable deficiency. More than one discrepant flow channel in a bay is not acceptable, however. These requirements are based on the sensitivity of the partial blockage analysis to additional blockage. The Frequency of 9 months was based on ice storage tests and the allowance built into the required ice mass over and above the mass assumed in the safety analyses. SR 3.6.12.5 Verifying the chemical composition of the stored ice ensures that the stored ice has a boron concentration of at least 1800 ppm as sodium tetraborate and a high pH, 2 9.0 and s 9J in order to meet the requirement for borated water hb30*Da wnen the melted ice is used in the ECCS recirculation mode ' of operation. Sodium tetraborate has been proven effective in maintaining the bcron content for long storage periods, ) and it also enhances the ability of the solution to remove l and retain fission product iodine. The high pH is required to enhance the effectiveness of the ice and the melted ice in removing iodine from the containment atmosphere. This pH range also minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to ECCS and Containment Spray System fluids in the recirculation mode of operation. The Frequency of 18 months ] was developed considering these facts: ;
- a. Long term ice storage tests have determined that the chemical composition of the stored ice is extremely stable;
- b. Operatin; ex;.rience las demonstrated that meeting the boron cona ntrat w und pH requirements has never been a problem; ed
./ (continued) ; ~ (7 ./ { McGuire Unit 1~ B 3.6-81 l M W 20/07 L y e.a
~. . ..
__--__ u
Ice Bed B 3.6.12 l O~ BASES i i SURVEILLANCE ~SR 3.6.12.4 (continued) REQUIREMENTS. of frost or. ice > 0.38 inch thick, a representative sample of 20 additional flow channels from the same bay must be ! visually inspected. If these additional flow channels are all found to be I acceptable, the discrepant flow channel may be considered single, unique, and acceptable deficiency. More than one discrepant flow channel in a. bay is not acceptable, however. These requirements are based on the sensitivity of the partial blockage analysis to additional blockage. The . . Frequency of 9 months was based on ice storage tests and the L110wance built into the required ice mass over and above the mass assumed in the safety analyses. SR 3.6.12.5 Verifying the chemical composition of the stored ice ensures that the stored ice has a boron concentration of at least 1
<800 9.5Ippm as sodium in order to meettetraborate the requirement and a for highborated pH, 2 9.0 water and
@ 70* h O when the melted ice is used in the ECCS recirculation mode of operation. Sodium tetraborate has been proven effective in maintaining the boron content for long storage periods, and it also enhances the ability of the solution to remove and retain fission product iodine. The high pH is required to enhance the effectiveness of the ice and the melted ice l in removing iodine from the containment atmosphere. This pH range also minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to ECCS and Containment Spray System fluids in the recirculation mode of operation. The Frequency of 18 months was developed considering these facts:
- a. Long tem ice storage tests have determined that the chemical composition of the stored ice is extremely stable; I-
- b. Operating experience has demonstrated that meeting the boron concentration and pH requirements has never been a problem; and (continued)
McGuire Unit 2 .8 3.6-81 S W h 5/EC,/97-
Ice Bed Gee FA<*r] 2 B 3.6. g anscs
~ $URVEILLMICE SR 3.6. (continued)
REQUIREMENTS . . Frequency of 9 months was based on ice storage tests and the allowance built into the required ice mass over and above the mass assmed in the safety analyses. 3R 3.6. 5 Verifying the chemical composition of the stored ice ensures that the stored ice has a boron concentration of at least e $1800( ppa as sodiun tetraborate and a high pH, a (9.06and 7@ Q MO C , gg,g.in order to meet the requirement for berated water unen the melted ice is used in the ECCS recirculation mode of operation. Sodium tetraborate has been proven effective in maintaining the boron content for. long storage periods, and it also enhances the ability of the solution to remove and retain h ssion product iodine. The high pH is required to enhance the effectdveness of the ice and the melted ice in removing iodine from the contairment atmosphere. This.pH range also minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to ECCS and Containment 5 pray System fluids in the recirculation mode of operation. The Frequency of O8 p418Fmonths was developed considering these facts:
- a. Long term ice storage tests have determined that the chemical composition of the stored ice is extremely stable;
- b. Operating experience has demonstrated that meeting the boron concentration and pH requirements has never been a problem; and
- c. Soseone would have to enter the containment to take the sample, and, if the unit is at power, that person would receive a radiation dose.
hib 4 SR 3.6. 5.6 cccss, This SR ensures that a representative sampli of 'ce baskets, which are relatively thin walled, perforated cylinders, have not been degraded by wear, cracks, corrosion, or other damage. Eadi ice basket sust be raised at least 12 feet for this inspection. The Frequ mcy of (continued)
-40PS1"S,, B 3.6-158 Rev 1, 04/07/95 Mclisuvla
+
1 McGuire & Catawba Improved TS Review Comments
- ITS Section 3.6, Containment Systems
{ l 3.6.12-5 CTS 4.6.5.1.c (McGuire) ) CTS 4.6.5.1.d (Catawba) l ITS SR 3.6.12.6 and Associated Bases CTS 4.6.5.1.c (McGuire)/ CTS 4.6.5.1.d (Catawba) requires visually intpecting the " accessible portions" of at least two ice baskets. The phrase " accessible portions" has not been adopted in ITS SR 3.6.12.6 or its Associated Bases. No justification has been provided for the proposed change. The deletion of this phrase would make ITS SR 3.6.12.6 More Restrictive that the CTS; while relocating it to the Bases would make the change Less Restrictive (LA). Comment: Revise the CTS markup and provide the appropriate discussion and justification for this More/Less Restrictive change. DEC Response: j l This phrase has been relocated to the Bases using existing LA.14. I O l i .' mc3_cr_3.6 3.6-45 March 12, 1998 ___a
. Ice Bed i B 3.6.12 l 73 '
1 BASES l J SURVEILLANCE SR 3.6.12.5 (continued) l 8 REQUIREMENTS
- c. Someone would have to enter the containment to take the sartple, and, if the unit is at power, that person would receive a radiation dose.
SR 3.6.12.6 c, { This SR ensures that a representative samplingof ce baskets, which are relatively thin walled, perforated cylinders, have not been degraded by wear, cracks, corrosion, or other damage. Each ice basket must be raised at least 12 feet for this inspection. The Frequency of 40 months for a visual inspection of the structural soundness of the ice baskets is based on engineering judgment and considers such factors as the thickness of the basket walls relative to corrosion rates expected in their service environment and the results of the long term ice storage testing. O d REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50, Appendix K.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
f^ b).
-i McGuire Unit 1 8 3.6-82 JWW L /ZG/97 5 L -=
Ice Bed B 3.6.12 BASES SURVEILLANCE 3 3.6.12.5 (continued) REQUIREMENTS
- c. Someone would have to enter the containment to take the sample, and, if the unit is at power, that person would receive a radiation dose.
SR 3.6.12.6 (uMMtJ se%g i This SR ensures that a representative sampling of ice I baskets, which are relatively thin walled, perforated I cylinders, have not been degraded by wear, cracks, corrosion, or other damage. Each ice basket must be raised at least 12 feet for this inspection. The Frequency of 40 months for a visual inspection of the structural soundness of the ice baskets is based on engineering judgment and considers such factors as the thickness of the basket walls relative to corrosion rates expected in their service environment and the results of the long term ice storage testing. A U REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50, Appendix K.
- 3. 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
i' s s'. O McGuire Unit 2 B 3.6-82 // N /ZG/ F i
. I
. 6/8ec.a bMv1 3.0.12-t .
N' (MMeseENT SfffSs5 suRVElf I amer __.------.i fr==e!- 'l fl Toshot each f tal Ross 1, 2, 4, 6, 8. and f (or ros the same raw of adjacent har if a hasket fres a de emeted row cannot he feedformetWilag)withiseachboy if any ,g castets less then test of ce, a besket is t the same i .r. .: :"a*1 ve dad. le of 20 ddittenal ts f hear shell be The stateus everage weigh of ice from the as adet emel heshots and the discrepent he shall not ; g " . ant - " W at a t u leve of confi h .1 Tid ice condenser shall aise he sehdivided late 3 roups of SA, 3,6./2 3 eshets, b as follows: Grow 1 - Bays I threagh s, $ce, 2 - ears 9 through 16 and Geesp 3 - Boys 17 through 24. The stai-ames everspe Ice welpht of the semple hashets from ansial Reus 1, 2, 4. 4. 3 and e te each eroep shall met he s than 1881 pounds" ^ ae'1 eu leer -- 4,, The stalener total it.e condenser ice weight at a Sh4 level of 64 3 4,IL 2.3 confidence shall be calcolated esieg all ice basket weights _
~
detersteed duriae this weichlee severes pas sasis aos ne less a L ,,f2., a. .an z,ses m peuses ane g verifyiss, by a visual laspectise ,=_ = - - - . _- .R 3.(, . /2, 4 - letten of frost er ice SK g ..-- _ f _ , , r , - -- -. __
. . . . . . . ..9
,_1**f'#8'? "'8 ** d'*" b- , t'**!"8 ** M.._ 3*"J .
Abd ht< 4 P6 thickness of less than er _m i. . egeal to 9.BB,lgch.Sfest fice with a t7h chases of greater them er equal to 0.38 fach, e I err esseI 6 g c.oy g(q-4 4 su7 r* **4 k N sc6 representative sample of 30 adfitional flew passages free the , same her shall he viseelly loo lpaeses een faend acceptable,pecte d If these addittamal flI the surveillance program any I
@Ceade'4Se t- 'I proceed considering the slagle deficiency as amigue and accept able. leere them one testricted fleu sessage per har is AJ avih of sheermal doeredettee of the ice condenser.
visedliy les 6 -- I gg, 5 (,, /2, (,- @ At .1, east once per 40 muerths I messisse --- - == b use
^
tuo ice beskets from each
. . - _ - . _ L, _ _ :. _ ~-
- . -- -. m-detriemetal structasrel user, c' recks corrosies er,other damage. .
uw _ _- --- urso se reises at : - - . .. .- i yo4 4
> G secelaf . WIT 1 3/46-21 Amonshunt No. 166 I
i l I i 'U P, 2 ,n. t
._.h
l'
. foeufa./wh 34./2 ^
m oraim mer s m a n @ 'f eensreeeamer , frs 1 f1 bashrt each assial asus 1 2, 4, 6. 8. and 3 (or see same row of essesset her If e hastet frus a deel row commet he feed for totWitag) witMa oesh her. f ear hoekst is to contate less them 1801 of f .e y ,f representati saeple of II additiesel free seen .. - her shall gelched. De slotela everept neight lee from. the as Gemel baskets and the discrapest i shell notJ 3001 poundar - at a ese t - m - --.1 he less 1he ice esadameer shall also be sehdivided late 3 of g J,f,,/;* - 3 2 baskets, as folleus: Gresqs31.. Says toys 9 thromah 14 SaysIT 1 through thrsagh 8 M. The stof. i semple baskets free nedsat sin ever pe Ice w. andasus 1. 2. 4. 4 8.ght ofand 9 la oesh grou left peanesthseliet at a 984 lowl of confidamee.* The stateau total les condesser les telebt at a 30% level er esafseesse shsts he caleuested meter elf too beshet wetehes _
- 84. 3.6./2 #2.) detereleed dertes tMs wiWileg preargsfansen not se less enen z ess.res poeness amm ,
g 34, q -
'd serifytes, hr a wisest taspectias m -. -- - -
y s &,/2 d g . , , , , _ __ ___ . _'accummistion_of frost er ice- O E,J W 888" A888* fl$fr*tiU Mh h I,,r. .tch e a - t .r _ _ _ - i s. ... . _ t _ .hmfront
- er m
i Ice eith a IM, . et greater then er aquel to .3B fach, a ggff suspie of as aestatemet flew from tem supresentet same her she he vismett found tes%y tempactes. If stemet new may f*%hM K C. pecesses the serve (11
~
. - , - ene are t e, e,s i
e per her_is . g u u . .u . i .__ e ,.rd. 4 esesee.- bashnesrs fromii,.enehpt .,, l __._- - _ _ - - - - - i- _ , ,,,, I estrimental structurel user cresis, servestem. er other essem. ~
;^_ _M - ;a - ^
a - i r ._;. ' g *^ ^ u.m n 4f& ph Nk fb b Ile W I E . IETT I 3/4 6-21 Amendoset he. 148 g 2 d
j Ice Bed dce t w e. a g, 8 3.6. g e4SES
~
SURVEILLANCE SR 3.6. (continued)
. REQUIREENTS Fregency of 9 months was based ca ice storage tests and the allowance built into the required ice mass over and above the mass assumed in the safety analyses.
3R 3.6. 5 Verifying the chemical composition of the stored ice ensures that the stored ice has a boron concentration of at least 4 M V ,C
$1800( ppe as sodium tetraborate and a high pH. = 19.06and c JL9.5Lvin order to meet the requirement for berated water %
men tne melted ice is used in the ECCS recirculation mode of operation. Sodium tetraborate has been proven effective in maintaining the boron content for long storage periods, and it also enhances the ability of the solution to renove and retain fission product iodine. The high pH is required to enhance the effectiveness of the ice and the melted ice in renoving iodine from the containment atmosphere. This pH range also minimizes the occurrence of chloride and caustic stress corrosion on mechanical s stems and components exposed to ECCS and Containment System fluids in the % reci lation mode of operation. Frequency of
. I g 18 months was developed considering these facts:
- a. Long term ice storage tests have determined that the cinunical composition of the stored ice is extremely stable;
- b. Operating experience has demonstrated that meeting the boron concentration and pH requirements has never been
.a problem; and
- c. Someone would have to enter the containment to take the sample, and, if the unit is at power that person would receive a radiation dose.
y Orb SR 3.6. 5.6 cces3, This SR ensures that a representative sanpling of 'ce baskets, which are relatively thin walled, perforated cylinders, have not been degraded by wear. cracks, corrosion, or other damage. Each ice basket sust be raised at least 12 feet for this inspection. The Frequency of (continued) 9
-4d881?fr, B 3.6-158 Rev 1. 04/07/95 HClvuvl-
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems V - 3.6.13 Ice Condenser Doors 3.6.13-1 DOC A.1 CTS 4.6.5.3.2.a ITS SR 3.6.13.2 CTS 4.6.5.3.2.a requires verifying that the intermediate deck doors are free of frost accumulation. ITS SR 3.6.13.2 requires verifying that the doors are not impaired by ice, frost, or debris. The proposed change has been categorized as an Administrative format change (DOC A.1). The proposed change is not an Administrative change but a More Restrictive change since it adds requirements (ice and debris). Comment: Revise the CTS markup and provide the appropriate discussion and justification for this More Restrictive change. Revise the CTS markup and provide the appropriate discussion and justification for this More Restrictive change. DEC Response: The CTS markup and discussion of changes have been revised to add DOC M.9 to reflect this change. o -vo., s.~ e m ,ch 12. 1,,e
St ecdcuJrivs 3c.13
@~
.m - -
esmerttemarr esenstasensurs fcantiwi [k~Testingeach of thedeer deers and veri tuguired to each free closi is ing that the wgue] greater 74 lach-peands the door is 40 degrees opea. Thi torque is defined as " deer closing torque
- and is equal the I meniset r torgue eines a frictional targue I and
$ Calcola sa of the frictional targue of each tested in with3)and4),above. The calce frictional t shall be less than er equal te de 4 -peands.
- s. Intemodiate Deck Beers . Each ice condenser inteWate Weck deer sEs I doed w ael m m .eJ beg n Q verifb Mazar shib M MeO*E g inspecties at least once per 7 f letten by a visuoi b MF ,
. and g4. 3.6./8 7 $ Demostnted OPfustEAtta i este per s -----
r 1 ' ' dat least once per 18 months thereafter by visually verifying as structeral deterioretten, f fying free novament of the vest assentiles, free sevement - n - - r= ran ema n c-e . . . .r iern ggg Liftige Forc h
~
! Adjacent to c well Egeel to er less then 37 41 2 Peired with adjacent to crene we .Egeel to er less then .8 165
{ 3) Adjacent contaianset tiell Egeal te er less 31.4 lbs. M'3 and paired thdeeradjacent j , to tament mall Essel to er less 31.0 lbs. 54 74.G,3 r1rw r, T., geek Seers . Each ice condameer top dock deer shall'he deter. eined em OPEmeLE et least one per 92 days by visually verifying:
- a. h t the doors are in place, and
- b. ht as condensaties, frost, or ice has formed en the deers dp artausstB ukick weeld restrict their lifting and opening (Ctenutruf. O 'I gesaggg . gati 1 3/4 6-N Amendmast me. 166 lhe 2dz.
3,G.t3
&.a. . . .. ,n GMTM ITITBIf
- m amer ;; tr a - a f4) Testing each regetred to of sne esers and vertfytop that the each deer from cleslag is grooter 3 ]
lech-peuses the deer is 40 degrees spen. Thi tergne is defiand ' deer clesfag targme* end is aquel the torque stase a frictiesel tefgue ; and mesteel 4f
) Calcol som of the frictiesel torgue of eed tested te with 3) and 4), above. 1he calcul frictiesel shall be less them er essel to es i .
sws-n setermedteu sed seere . _seen see e adeseer sneermeetet doek deer r r
*h*'I h**
y M s.a/ **t manned by occar) - g M,1 54 3.4.15,2. go verfoss asEar freetdiioammletten by a vtemai - taspection at least asce per 7 ders, and
.54.16. G. 7 e commersted oPSMELgE_.
_ a s._ _a_ n_ -= f m' asset J least emos eenths thereafter by visually vertfytag me structors
-n- @- as -
lem, br vertfytes free op of the vent essese11 ,.
@ free _ @* 4asC n---- --
m Lifties Feree '
- 1) Adjeesst te emil Equal to er less 37.4 h ,
- 2) relegd wie adjacent to creme 1- Equal te er 1 thee 33.8 es
- 3) edia==t eestatement unti Equal to or 1 then 31.4 h ,,. M and
- 4) Feired th door adjeesst l to amant men Equal to er ens ese 31.s *).
Tap Deck esers . Each les esadenser top deck door shell he deter-f4 J.(,.I3 3 tand s M opemeLE et least esos per 92 ders by viemelly verifytes:
- a. That the deers one is place, and
- b. 1 tat as eendemeattee, freet, er tee has formed as the doors e erfumEth eid useld fostrict their lifting and opening N.
IkeflE = leIIT 2 3/4 6 34 Amendesat he. 140 O Pf q 2of 2
Discussion of Ch:nges Secticn 3.6 - Containment Systems TECHNICAL. CHANGES - MORE RESTRICTIVE M.5 Not used. M.6 Not used. M.7 An additional surveillance is proposed for CTS 3.6.1.7 to verify each door in each access opening to the reactor building is closed, except when the access opening is being used for normal transit entry and exit. This additional surveillance is acceptable because the integrity of the reactor building is important to the dose calculations following a DBA and it is required by CTS 1.27.a. This change is considered more restrictive because it requires additional surveillance beyond that which are presently performed for the reactor building integrity. This change, retained in ITS 3.6.16, is consistent with NUREG-1431. H.8 CTS 3.6.4.3 Actions provide actions for inoperable hydrogen igniters. If these actions con not be satisfied, CTS LCO 3.0.3 must be entered which requires action within 1 hour or a shutdown to MODE 3 in the following 6 hours. ITS 3.6.9 requires that if these some actions cannot be met the plant must be placed in MODE J 3 within 6 hours. This change is slightly more restrictive since the CTS would provide 1 additional hour. This change is acceptable because it places the plant in a MODE where the specification is not applicable. This change is consistent with NUREG-1431.Not =cd. M.9 CTS 4.6.5.3.2.a requires verifying that the intermediate deck doors are free of frost occumulation. ITS SR 3.6.13.2 requires verifying that the doors are not in. paired by ice, frost, or debris. This requirement is more restrictive than the current stated requirements, however, it is consistent with existing operating practices and with NUREG-1431. A U McGuire Units 1 and 2 Page M - 23 Supplement 25/20/97l
McGuire & Catawba Improved TS Review Comments f ITS Section 3.6, Containment Systems t 3.6.13-2 DOC A.1 CTS 4.6.5.3.3.b ITS SR 3.6.13.3.b (McGuire) ITS SR 3.6.13.7 (Catawba) CTS 4.6.5.3.3.b requires verifying that no condensation, frost, or ice has formed on the top deck doors or blankets. ITS SR 3.6.13.3.b (McGuire)/SR 3.6.13.7 (Catawba) only addresses the doors; it does not address the blankets. The proposed change has been categorized as an Administrative format change (DOC A.1). The proposed change is not an Administrative change but a Less Restrictive change. Comment: Revise the CTS markup and provide the appropriate discussion and justification for this Less Restrictive change. DEC Response: The top deck doors or " blankets" are the same component and the words are used interchangeably. Therefore, there is no reduction in requirement. I v Q h mc3_cr_3.6 3.6-47 March 12, 1998
McGuire & Catawba Improved TS Review Coments ITS Section 3.6, Containment Systems O t 3.6.13-3 A.28 CTS 4.6.5.3.1.a ITS SR 3.6.13.1 CTS 4.6.5.3.1.a requires that the ice condenser inlet doors be continuously monitored and determined closed by the inlet door position monitoring system. ITS SR 3.6.13.1 requires verifying all inlet doors indicate closed by the inlet Door Monitoring System with a frequency of 12 hours. The proposed change has been categorized as an Administrative change (DOC A.28). The proposed change is not an Administrative change but a Less Restrictive change (Continuous to 12 hours). Comment: Revise the CTS markup and provide the appropriate discussion and justification for this Less Restrictive change. DEC Response: The CTS markup has been revised and DOC A.28 has been replaced by DOC L.29. O mc3_cr_3.6 3.6-48 March 12, 1998
i fp[s Lg.hte n S' Y' 0 ( . k 3 (p CWIIAllEERT SYSTDil
- 3. (p .13 ICE M W
,.....-.....---.-,,u, EZEP The Ice condenser inlet deers, interisediate deck doors, and tee doch m 54. s3 < doors shall be closed and GrensLE.
APPLICASILITY: MODE 5 1, 2. 3._and g., kg ets (4.bW sh is alleM AM E8 . _C.._mk ict Coaltasce bio'"- 47q y a. With one er more ice condenser deers spea er otherwise ineserable ht _ c 7 's. as -yme =e :4n11vt _iyuuta UrtaAll0N any continue for g to AvreA/ 5.1- 14 days .v. -isse sue icu umu _ _ . . . in n ... es . .. - m . hours and the maniamme ice had teoperature is maintaleed le.s than er 85 T' M 8*/ mama 1 ta 27'Ft.- ^^ - se, --. zus - . to the1e c1esei seeitiens er gfjoy c, OPDMBLE states (as appitcabiel withia 48 hoursier se in 4, seast m1 as-. witnie sue most e asers and in EUw 3NUTDelet withis the following M 7ded/ O 30 hours
~ ACTI0d A $ Withw ame-sca11v).
er more restere ice condoneer all daerndoors en Nineserehte 8 states withes (not capable 1 hearof opdeni en NDT 5- __
.. ..n n Jar re s . - . ; I p g t) __ la .CRBwissin e hourswithin SETTORIl and E-tw followleg 3e neers. )
$URVEILLAntf REGutitBENf3 6 talet Beers - fee condenser islet deers shall her M 4 rd N M As L g 3,g,,gg,/ 3 ^-- ==d M ---S 335by the talet deer i posttien annitoring system. and C Demonstrated OPOWALE forTugjmBt att once per la seeths kyr R 3,4.17,6 @ vertfries that the tergue required to tattially spee esca aeor is less than er egeal to 675 inch poeness
- g. .c. . a. y e verifr a each deer i
-- - _syst,,a !s nos tapeares my ice, frost.gesens.A=
.m & @
M 5.(m'.II' O -eac$i ese of _the . odeers less pthan vertfri 1 5 "i
--sne.. ,
{ the door is 40 spea. This targue i med as the l#4f
" deer egen
- and is eget1 to the esl deer to les a frt 1 1--- - e ^.7 b dL dOW #
McGUIRE - WEIT 1 3/4 6 23 Amendment me. 166 l P4 . I o f 2. r 1
Spehwhoo 3.G.t3
- 3 0 5*h
- 5. (,,, /J WM rcr camissa assu
- i TElfTM m'fle pm apsmatidhe
/,cp J4,g 6 The les condense.* Selet deers, latermediate dock doors, and top dock doors shell be closed and OPEMBLE.
APPLEeRILIHs M8 t/N. Sagarsktd. IEWE51. M Cc 2. 3. and Am_kn dN 4wkio c k u '6e-griou a e wth am er more ice condenew deers esse er otherwise temperable (het 9- of "r - callyl._ _ -.sen my _..__ ryr up w 4CT/*u A1 days
.Q mg m , =_ . _ i S E E ne leef d er AN 8 / eseel te tr r e ___...se resu re see emers = _ ., a . ... w Acy,e,y C, _ _ _? etates (as aselItablel wittle 48 hourspr se in es seest suru as _ . ..... seu next a esses and se sour _. -- witerts the fellewley A W 84/ D 30 heers.
pg4 9 with one w^callw1. eere __^_ fee xW all deers de rs to i i le (not esse 6te ef esset
^
states withte 1 hear to IER ITM Witate 5 meers ie vu ser _ _ ..."_..# I M* MT/'dM M gend la (R$ M W tote Ese fellesteg 35 . .. entfrft t AMT ,a
-~
6 !alet essrs . Ise esademmer telet deers shell tes .M ft fhQ 6# J.(e.fl./ @ Mametterd and deteredenSciesed by the telet door positism esettertog syneen, and b esamestrated erum sLE[- . ; ___ . _ et least esos per is emeths byt
$4. J. G.17. f S verifytes that the targue reentred to lettially spee each deer te less them er aquel to SFS test passess
,$4, 3,(,, / 7. _4 f- @ verifym each deer is --
. m -- -si-=
g - i. - e, ice,fr-t e n . . (A I6. /3, 6 $ each see of the deers
. . , _ . . . . . is less thee I i the door is 40 epen. Ilds teripse is Miined as the .)
*eser speet and 1s agust to see i eser t eles a frtet terase cessenet;r fer$ won d bryat bt'$Y 0!\
IteWIM WIT 2 3/4 6-23 Aemndesst Ile. 148 Pqs Id z
Discussten of Chrnges Section 3.6 - Containme:;t Systems ADMINISTRATIVE CHANGES (V , This Action specifies that with the heaters inoperable, the heaters must be restored to operable status within 7 days or l action initiated in accordance with ITS 5.6.6. ITS 5.6.6 requires ! the submittal of a written report containing the reason for the inoperability of the heaters and the planned corrective actions. No technical changes are made and this change is considered I administrative. , i i 1 A.25 Not used, i A.26 CTS LC0 3.6.1.8 Surveillance Requirements require the testing of ventilati.m filters in accordance with Regulatory Guides and ASTM codes. N 3e detail requirements have been moved to the Administrative Controls, ITS Chapter 5.0. A new surveillance is added to CTS 3.6.1.8 and retained as ITS SR 3.6.10.2 to require testing in accordance with the Ventilation Filter Testing Program as described in Chapter 5.0. This change is considered administrative. Any technical changes to these requirements are discussed in the Discussion of Changes for Section 5.0. The change is consistent with NUREG-1431. ( A.27 A Note is added to CTS 3.6.5.3 which permits separate condition entry for each ice condenser door. This change is necessary to provide explicit instructions for proper application of the ACTIONS for Technical Specification compliance. In conjunction with ITS 1.3, " Completion 7 M :," this Note provides direction consistent with the intent X 4e existing ACTIONS for inoperable ice condenser door and is tAY. more, considered administrative. This change, retained in ITS 3.6.13, is consistent with NUREG-1431. A.28 Not used. CTS 4.5.5.3.1.c. require; continucu;ly monitoring inlet door p;;ition:. ITS SR 3.5.13.1 provide; cxplicit instruction; cf "cVery 12 hours." Continuou; monitoring cf inlet dccr pc;ition i; accomplished by the Inlet Decr Pc;ition "cnitoring System, CTS 2.5.5.4. Thi; :pecification, howcVer, i; relocated frc the TS :: disc;;;cd in P,.2. The requirc cat of 12 hour; i; c;tablished cen;istent with the =cnitoring of ice bed ic peraturc ;ince temperature i; the concern with on open decr. Providing , clarification by giving an explicit frcquency for the ;urveillance I fm i; con;idered admini;trative. Thi; change i; con;i; tent with
.() NUREC-1431.
McGuire Units 1 and 2 Page A - 77 Supplement 25/20/97l
Discussicn cf Ch:nges Sectia 3.6 - Containme:.t Systems O v TECHNICAL CHANGES - LESS RESTRICTIVE L.27 CTS 3.6.4.3 does not include an Action for the Condition where
- there is no OPERABLE hydrogen igniter in one containment region.
ITS 3.6.9 adds this new condition and requires a hydrogen igniter be restored in the affected containment region to OPERABLE status within 7 days or be in MODE 3 within 6 hours. This change provides actions consistent with a footnote to CTS Surveillance 4.6.4.3.a which requires that inoperable igniters not be on redundant circuits in the same region. CTS 3.0.3 would be required to be entered if this condition existed in the CTS. This change is acceptable because of the low probability of an event occurring within the 7 day completion time that would generate an amount of hydrogen that exceeds the flammability limit and the I availability of the hydrogen recombiners, hydrogen skimmers, and l hydrogen monitors. This change is consistent with NUREG-1431. L.28 CTS 4.6.3.2, 4.6.2.c, 4.6.5.6.1.a. 4.6.5.6.1.d, and 4.6.1.8.d.2 require that the specified testing be performed using a " test" signal. ITS SRs 3.6.3.76, 3.6.6.3, 3.6.6.4, 3.6.8.4, 3.6.10.3, l 3.6.11.1 and 3.6.11.3 pennit the use of an actual or simulated l O. actuation signal for testing purposes. This change permits credit !O to be taken for unplanned events (cctual sigaals) which provide the necessary data to satisfy the SRs. The actual signal is what l is credited within the safety analysis and is sufficient for demonstrating compliance with the SRs. This change is consistent with NUREG-1431. L.29 CTS 4.6.5.3.1.a requires continuously monitoring inlet door positions. ITS SR 3.6.13.1 requires the door positton be monitored every 12 hours. Continuous monitoring of inlet door position is accomplished by the Inlet Door Position Monitoring Sys tem, CTS 3. 6. 5. 4. This specification, however, is relocated from the TS as discussed in R.2. The requirement of 12 hours is a less restrictive change. The proposed change is acceptable since the 12 hours is consistent with the monitoring of ice bed temperature which is the parameter of concern with an open donr. L.30 CTS 4.6.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room are sealed closed. ITS SR 3.6.3.1 verifies that these valves are sealed closed but provides an exception to open one purge valve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs. p) ( The exception was added to establish the allowance of opening a McGuire Units 1 and 2 Page L - 10M Supplement 25/20/07l
No Signffic= t H:z:rds Consid: ration Sectica 3.6 - Cont inment Systems (q LESS RESTRICTIVE CHANGE L.29 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specificattons, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.5.3.1.a requires continuously monitoring inlet door positions. ITS SR 3.6.13.1 requires the door position be monitored every 12 hours. Continuous monitoring of inlet door position is accomplished by the Inlet Door Position Monitoring Sys tem, CTS 3. 6. 5. 4. This specification, however, is relocated from the TS as discussed in R.2. The requirement of 12 hours is a less restrictive change. The proposed change is acceptable since the 12 hours is consistent with the monitoring of ice bed temperature which is the parameter of concern with an open door. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications
'N change and determined it does not represent a significant hazards (A consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?
The proposed changes extends the monitoring of ice bed door position from continuous to once per 12 hours. The frequency of surveillance tests are not considered initiators of any analyzed event. Therefore, the probability of an accident previously evaluated is not significantly increased. The proposed change does not reduce the performance requirements or acceptance criteria for the systems or components, therefore, the consequences of analyzed events are not affected. i (~ ( McGuire Units 1 and 2 Page 5861 of 6363 Supplement 25/20/97l
N3 Signific:nt H:ztrds Cusid:irati:n 3::ctica 3.6 - C:ntainment Systems
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The propose? change does not permit operation in a new or different mode, or permit the installation of a new or different type of equipment. The proposed changes extends the monitoring of ice bed door position from continuous to once per 12 hours. The affected systems and compo'1ents remain capable of performing their design safety functions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from those previously evai'uated.
- 3. Does this change involve a significant reduction in a margin of safety?
Th troposed change cor.tinues to require the some performance and acceptance criteria assamed within the safety analysis for these systems and components. The monitoring of door position is of interest for maintaining ice bed temperature. The survetIlance frequency for this paramater is already 12 hours. Therefore, this change does not involve c significant reduce a margin of safety. A b ( McGuire Units 1 and 2 Page 59 R of 6363 Supplement 25/20/97l
\
t McGuire & Catawba Improved TS Review Comuments ITS Section 3.6, Containment Systems G 3.s.13-4 DOC M.4 CTS 3.6.5.3 ACTION b (TS 3.6.13 ACTION D CTS 3.6.5.3 ACTION b requires that with one or more ice condenser doors inoperable (not capable of automatic opening) and not restored to OPERABLE status, that the unit be in MODE 3 in 6 hours, MODE 4 within the following 6 hours and MODE 5 within the following 30 hours. ITS 3.6.13 only requires the unit to be MODE 3 in 6 hours and MODE 5 within 36 hours. The requirement to be in MODE 4 within 12 hours of the commencement of a shutdown has been deleted. The justification (DOC M.4) used states that the deletion is a More Restrictive change. This is incorrect. The change is Less Restrictive, since the ITS does not specify a time limit in which to reach MODE 4. Comment: Revise the CTS markup and provide additional discussion and justification for this Less Restrictive change. DEC Response: The overall change is more restrictive since the CTS allows a total of 42 hours to reach MODE 5 (out of the mode of applicability) and the ITS only allows 36 hours to reach MODE 5. It is not the practice of the ITS conversion to dissect every phrase, but rather to capture the substance of the change. In this case, the actions are directing a unit shutdown and the desired MODE is MODE 5. Therefore, the ITS is mere restrictive than the CTS requirement O with respect to a unit shutdown. I l
\
g c 3_cr_3.6 3.6-49 March 12, 1998
i McGuire & Catawba Improved T5 Review Cannents ITS Section 3.6, Containment Systems 3.6.13-6 JFD Bases 11 STS B3.6.16 Bases - RA B.1 and B.2 and RA C.1 ITS B3.6.16 Bases - RA B.1 and B.2 and RA C.1 The last sentence in STS B3.6.16 Bases - RA B.1 and B.2 states the following: "If this verification is not made Required Actions D.1 and D.2 not Required Action C.1 must be taken." in addition, the last sentence in STS B3.6.16 Bases RA C.1 states the following: " Condition C is entered from Condition B only when the Completion Time of Required Action B.2 is not met or when the ice bed temperature has not been verified at the required - frequency." Both of these statements have been deleted from ITS B3.6.16 Bases - RA B.1 and B.2 and RA C.1 respectively. The justification for this deletion (JFD Bases 11) states that the Bases discussions are not consistent with the specification nor with the rules of Completion Times as defined in NUREG Section 1.3. The staff believes that the two statements are correct and need to remain. The staff's interpretation of the statements is that if the ice bed temperature is not surveilled in accordance with the frequency limitation specified in ITS SR 3.0.2 due to forgetfulness or inattention to ACTION requirements, rather than inrability to perform surveillance, a shutdown is required, rather than allowing an additional 48 hours to restore the ice condenser door to OPERABLE status. In addition, the staff considers the change to be generic and beyond the scope of review for this conversion. Comment:- Delete this generic change. DEC Response: The staff's interpretation is neither consistent with the current technical specification requirements, STS 3.6.16 as written, STS LCO 3.0.2, nor with the rules of Completion Times as described in STS 1.3. The proposed interpretation is also inconsistent with the actions for the ice bed temperature LCO 3.6.12. The stated action in STS 3.6.16, required action B.1, is to verify ice bed temperature is within limits on a periodic frequency of 4 hours and required action B.2 requires the inoperable doors be restored in 14 days. If at any time during the 14 hours, the temperature is not within limits, then required action C.1 becomes applicable and requires the ice condenser be restored in 48 hours. This is exactly the same action as required by STS 3.6.15, Required Action A.1. This action is also applicable (and intentionally identical) because with the temperature limit not met, the LCO is not met and the actions of STS 3.6.15 become applicable. In both STS 3.6.16 and 3.6.15, a completion time of 48 hours is allowed with the ice bed temperature not within limits. If the temperture limit is not checked, the STS Bases provide conflicting statements which also do not agree with the actions as written. The Bases for required action B.1 and B.2 state that if the verification is not made, condition D applies. The Bases for required action C.1 states that it applies when the temperature has not been verified at the required frequency. Condition D, however, clearly indicates in the Specification that it is only applicable to Conditions A and C. CTS 3.6.5.3 allows operation for up to 14 days provided the ice bed temperature is monitored every 4 hours and is within limits; otherwise, the doors must be restored in 48 hours. The mc3,,c r_3. 6 3.6-51 March 12, 1998
McGuire & Catawba Improved TS Review Coeucents ITS Section 3.6, Containment Systems STS Bases cannot establish new rules for the usage of completion times which are not consistent with those already established by STS 1.3, nor can the Bases direct actions which are in direct conflict with the actions of the LCO as written. The STS Bases is incorrect on both counts and is a more restrictive change on the current license. Duke Energy does not accept this more restrictive change for inclusion in the ITS, nor is this change from the STS Bases considered generic because it maintains the current licensing basis. O 1 9 e det g
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.13-7 CTS 3.6.5.3 ACTION b ITS 3.6.13 Condition A CTS 3.6.5.3 ACTION b states that "With one or more ice condenser doors inoperable (not capable of opening automatically), restore all doors to OPERABLE status within 1 hour." The CTS markup shows this statement being converted to ITS 3.6.13 ACTION A. ITS 3.6.13 Condition A only applies to ice condenser inlet doors while CTS 3.6.5.3 ACTION b applies to all ice condenser doors. No justification is provided for this Less Restrictive change - the other doors encompassed by CTS 3.6.5.3 ACTION b would fall under ITS 3.6.13 ACTION B. Comment: Revise the CTS markup and provide additional discussion and justification for this Less Restrictive change. DEC Response: The ITS has been revised, consistent with the current licensing basis, to reflect the CTS requirements and require the action be applicable to all doors. it is not clear why the STS would allow doors to be blocked for 14 days and Duke Energy cannot provide adequate justification for inclusion within the ITS. O 3.6-53 March 12, 1998
]r~% mc3_cr_3.6
Ice Condenser Doors-3.6.13 b d' 3.6 CONTAINMENT SYSTEMS 3.6.13 Ice Condenser Doors LC0 3.6.13- The ice condenser inlet doors, intennediate deck doors, and
' top deck doors shall be OPERABLE and closed.
APPLICABILITY: ' MODES 1, 2, 3, and 4. ACTIONS
--------------.----------------------NOTE-------------------------------------
Separate Condition entry is allowed for each ice condenser door. CONDITION REQUIRED ACTION COMPLETION TIME' A. One or more A.1 Restorehdoor to I hour condenser doors OPERABLE status. O inoperable cue to being physically restrained from opening. B. One or more ice B.1 Verify maximum ice Once per condenser doors bed temperature is 4 hours inoperable for reasons s 27'F. other than Condition A or not closed. AIE B.2 Restore ice condenser 14 days door to OPERABLE' status and closed positions. (continued) L[ McGuire Unit 1 3.6-32 8Vff c
/20/07
Ice Condenser Doors 3.6.13 ' 3.6 CONTAINMENT SYSTEMS i 3.6.13 Ice Condenser Doors LCO 3.6.13 The ice condenser inlet doors, intennediate deck doors, and top deck doors shall be OPERABLE and closed. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each ice condenser door.
--------..--s ---_------__--------_---__----_-__.---------------____-______--
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more ice A.I Restore Odoor to I hour I condenser @ doors OPEPABLE status. O inoperable due to O being physically . restrained from opening. B. One or more ice B.1 Verify maximum ice Once per condenser doors bed temperature is 4 hours inoperable for reasons s 27'F. Other than Condition A or not closed. AlH1 B.2 Restore ice condenser 14 days door to OPERABLE status and closed positions. (continued) O O 4 McGuire Unit- 2 3.6-32 JufP k *t V 5/?c/0P
Ice Condenser Doors B 3.6.13 BASES (continued)- ACTIONS ~ A Note provides clarification that, for this LCO, separate Condition entry is allowed for each ice condenser door. Al-If one or more ice condenser @ doors are inoperable due to being physically. restrained from opening, the door (s) must be restored to OPERABLE status within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour. Completion Time is consistent with the ACTIONS of LCO 3.6.1,
" Containment," which requires containment to be restored to OPERABLE status within 1 hour.
B.1 and B.2 If one or more ice condenser doors are detennined to be partially open or otherwise inoperable for reasons other than Condition A or if a door is found that is not closed, it is acceptable to continue unit operation for up to O 14 days, provided the ice bed temperature instrumentation is monitored once per 4 hours to ensure that the open or inoperable door is not allowing enough air leakage to cause the maximum ice bed temperature to approach the melting point. The Frequency of 4 hours is based on the fact that temperature changes cannot occur rapidly in the ice bed because of the large mass of ice involved. The 14 day Completion Time is based on long term ice storage tests that indicate that if the temperature is maintained below 27'F, there would not be a significant loss of ice from sublimation. If the maximum ice bed temperature is > 27'F at any time or if the doors are not closed and restored to OPERABLE status within 14 days, the situation reverts to Condition C and a Completion Time of 48 hours is' allowed to restore the inoperable door to OPERABLE status or enter into Required Actions 0.1 and D.2. Ice bed temperature must be verified within the specified Frequency as augmented by the provisions of SR 3.0.2. (continued)
.McGuire.. Unit'1 8 3.6-87 J yp h M $ ?^/W--
t
Ice Cond:nser Doors B 3.6.13 O. v BASES (continued)' I' 1 ACTIONS A Note provides clarification that, for this LCO, separate l Condition entry is allowed for each ice condenser door. 1 Al If one or more ice condenser @ doors are inoperable due to being physically restrained from opening, the door (s) must be restored to OPERABLE status within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis. The I hour Completion Time is consistent with the ACTIONS of LCO 3.6.1,
" Containment," which requires containment to be restored to OPERABLE status within 1 hour.
B.1 and B.2 If one or more ice condenser doors are detennined to be partially open or otherwise inoperable for reasons other than Condition A or if a door is found that is not closed, it is acceptable to continue unit operation for up to O 14 days, provided the ice bed temperature instrumentation is . , monitored once per 4 hours to ensure that the open or inoperable door is not allowing enough air leakage to cause the maximum ice bed temperature to approach the melting point. The Frequency of 4 hours is based on the fact that temperature changes cannot occur rapidly in the ice bed because of the large mass of ice involved. The 14 day l Completion Time is based on long tenn ice storage tests that l indicate that if the temperature is maintained below 27'F, there would not be a significant loss of ice from sublimation. If the maximum ice bed temperature is > 27'F at any time or if the doors are not closed and restored to OPERABLE status within 14 days, the situation reverte to Condition C and a Completion Time of 48 hours is allowed to l restore the inoperable door to OPERABLE status or enter into l Required Actions 0.1 and D.2. Ice bed temperature must be l verified within the specified Frequency as augmented by the provisions of SR 3.0.2. p (continued) U McGuire Unit 2 B 3.6-87 O ff bwf-b #0/9P 6
O. Ice Condenser Doors (Te, g 7 3.6 00MTAINMENT SYSTEMS 3.6. IceCondenserDoorsIIceJninWerD , o LCO 3.6. The ice condenser inlet doors, intemediate deck doors, and top deck fdoorsI shall be OPERABLE and closed. APPLICABILITY: MODES 1. 2, 3, and 4. ACTIONS
. .... . ... . . .. NOTE .. _ . . ... ......-... ....
Separate Condition eritry is allowed for each ice condenser door. ..
.. ... .... . .... ~ . -.. - . - - _ .. _ . . - ..
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more condenser doors A.1 Restore n %r to OPERABL s.atus. 1 hour inoperahl to CN being physically
'Q restrained from opening. -
t B. (be or more ice B.1 Verify maxista ice Once per condenser doors bed temperature is 4 hours inoperable for reasons other than Condition A s (271*f. @ or not closed. M B.2 Restore ice condenser 14 days door to OPERABLE
. status and closed
, positions.
(continued) E p- 3.6 56 Rev 1. 04/07/95 48ccus '
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i; m I Q) ' Ice Condenser Desrs nerumenwn I B 3.6. h BASES . ACTIONS A.1
~
(continued) If one or more ice condenser @ doors are inoperable due to being physically restrained from opening. the door (s) must be restored to OPERABLE status within 1 hour. The Required Action is necessary to return operation to within the bounds of the contaiment analysis. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1,
' Containment." which requires containment to be restored to OPERABLE status within 1 hour.
B.1 and B.2 If one or more ice condenser doors are detemined to be partially open or otherwise inoperable for reasons other than Condition A or if a door is found that is not closed, it is acceptable to continue unit operation for 49 to 14 days, provided the ice bed temperature instrumentation is monitored once per 4 hours to ensure that the open or inoperable door is not allowing enough air leakage to cause the maximum ice bed temperature to approach the melting point. The frequency of 4 hours is based on the fact that iQ temperature changes cannot occur rapidly in the ice bed 1 because of the large mass of ice involved. The 14 day (./ Completion Time is based on long term ice storaoe tests that indicate that if the temperature is maintained 6elow (27)eF. there would not be a significant loss of ice from @ siblimation. If the maximei ice bed temperature is > 07PF
-7 at any time' the situation reverts to Condition C and a @
( p3.dortb f or ( %1etion Time of 48 hours is allowed to restore the inoperable door to OPERABLE status or enter into Required s D.1 and 0.2. Ice bed temperature must be verified hd} c,n C9,) if within the specified Frequency as augmented by the visions of SR 3.0.2JIt this y canon is no OP6th ons u.1j6d 0.2, not ired Action 1,aust L _1 , If Req eired Actions 8.1 or B.2 are not met, the doors must be restored to OPERABLE status and closed positions within 48 hours. The 48 hour Conpletion Time is based on the fact that, with the very large mass of ice involved, it would not be possible for the temperature tog to the melting ue-se (continued) M !5 B 3.6-164 Rev 1, 04/07/95
& GusN-O G
i
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems V 3.6.14 Divider Barrier Integrity 3.6.14-1 DOC A.1 CTS 3.6.5.5 CTS 3.6.5.9 ITS LCO 3.6.14 and Associated Bases CTS 3.6.5.5 specifies that the personnel access doors and equipment hatches between the containment's upper and lower compartments shall be OPERABLE and closed. CTS 3.6.5.9 specifies that the divider barrier seal shall be OPERABLE. These requirements have not been retained in corresponding ITS LCO 3.6.14, but instead have been placed in the Bases BACKGROUND discussion for ITS B3.6.14. The proposed changes have been categorized as an Administrative change. The proposed changes are Less Restrictive (LA) changes. Comment: Revise the submittal and provide the appropriate discussion and justification for these Less Restrictive changes. DEC Resporise: The CTS markup and discussion of changes have been revised to add DOC LA.26 to reflect this change. O LJ t mc3_cr_3.6 3.6-55 March 12, 1998 i
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4A 3.6.(4'.E e The personnel access deers and equipm. ant hatches between the contalement's upper and leurr coupertments shall be determined OPEMBLE by visually tospecting the seals and sealtag surfaces of these penetrettens and verifytag me detrisental sisallgmumets, crects er defects la the seelfag surfaces, or apparvat deterterattaa of the seel materfel
- a. prior to final closure of the penetration each time it has been
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- b. __At least once ser le yearsifer penetrations containing seag
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suavCitLANCE araufADWITS kPir's The divider barrier seal shal.1 he determined OPDIASLE st least once per is months gering_ _ mbys 4t. 1 6.I /. y g memoving tue divider herrier seal test coupees and verifying that the phy.icei properties et the test coupe arey is ine-NE '^ " mm EM 19 ISBly J.3-J; f/lL 8). 6 li'h % Viseally inspectlag at least p5% of the Seel's entire length and: M the seal aan! seel stunting belts are properly h veri the seal esterial shows ne visual evidence of erstles due to beles, riptures, chemical attact, k abrasion, radiation damage, or changes in physical appearances. OfVinsa -- GE eras At'erpfans r pityTarAn wiid T N ILE sm,. <f.4 . r m srALs sr==} le 39.7 lbs 1st 11 IIceltaE - tatif 1 3/4 6-30 Ameneuet me. 166 O P, 2 J z
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5fasesy within the nest 6 hours and to 00La Stenghel within the followlag 30 ACYan(/ (,,,, heers. marriseamrs assurasuners f4, $/,Ne [ The personnel access doors and seet hatsdies betam6e the conta egent's teper and louer coupseements she I be deteredaed cleoed by a ) W,'N $o064 J visual leapecties prior teo_. e uma y =-i_.;w.m L ag _ m Mobdr6
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- a. prior to fleet closere of the penetrettes endi ties it has been opened,and h rettens centaining
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, , . _ . . , . . . . . _ _ _ m w..a.H-gg,. 3/,,/p g $ Vises 11y inspecting et least 90% of the seal's sottre length aed:
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? the seal and seal asustieg bolts eru properly Q verifydg3gst the seat estarial shoes se visual evidsece of deteriorettes doe to holes, rupteros, cheelcel attack, abrasien, radiation deesse, or cheapes in physical appearneces.
vaanr14.s f as Itust 4 TYpf SEALS STEEEfil . j je u./1. 9 \ 13 N.T Ibs
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Disc:ssi:n cf Ch nges Section 3.6 - C ntainment Systems n TECHNICAL CHANGES - REMOVAL OF DETAILS {) LA.23 CTS 4.6.3.2 requires performance of containment isolation valve ; testing during cold shutdown or refueling. This detail is not required within the TS to demonstrate operability and is relocated to the BASES for ITS SR 3.6.3.76. The Bases are subject to the l controls described in Chapter 5 " Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431. LA.24 CTS 4.6.2.b requires the containment spray pump meet a specified value when tested pursuant to Specification 4.0.5. ITS SR 3.6.6.2 requires that the pumps develop the required head pressure required by the Inservice Testing Program. Relocation of the required pressure to the Inservice Testing Program is acceptable since this program must meet the requirements of 10 CFR 50.55a. Changes to the procedures which implement these requirements are controlled by the procedure change program. These controls ensure that changes are appropriately reviewed and conform to 10 CFR 50.55a requirements. These changes do not change any technical requirements or change the present way of performing these V surveillances and are therefore considered administrative. These changes are consistent with NUREG-1431. LA.25 CTS 1.7 items a, b, c, and e define the attributes of containment operability and integrity. These attributes have been relocated to the Bases for ITS 3.6.1. The descriptive attributes are more appropriate information for Bases and are not necessary to be included within the Technical Specification. The requirement to maintain on operable containment is retained in ITS 3.6.1. The Bases are subject to the controls described in Chapter 5
" Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This ,
change is consistent with NUREG-1431. l LA.26 Descriptive information regarding the containment personnel access doors and hatches in CTS 3.6.5.5 and the divider barrier seal in CTS 3.6.5.9 is moved to the Bases for ITS 3.6.14. The movement of this information is appropriate because it involves details that are not necessary for inclusion in the LCOs and are more a appropriate for the Bases. The Bases are subject to the controls Y.] 1 l McGuire Units 1 and 2 Page LA - 7 Supplement 25/20/97l _- . ___ O
Discussicn of Changes S;cticn 3.6 - Conteinment Systems TECHNICAL CHANGES - REMOVAL OF DETAILS described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. These changes are consistent with NUREG-1431. LA.27 CTS 1.27 items a and c define the attributes of reactor building operability and integrity. These attributes have been relocated to the Bases for ITS 3.6.16. The descriptive attributes are more appropriate information for Bases and are not necessary to be included within the Technical Specification. The requirement to maintain on operable reactor butEding isretained in ITS 3.6.16. The Bases are subject to the controls described in Chapter 5
" Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431.
O McGuire Units 1 and 2 Page LA - 87 Supplement 25/20/07l
McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.14-2 DOC A.29 CTS 3.6.5.5 ACTION (McGuire) CTS 3.6.5.5 ACTION a (Catawba) ITS 3.6.1.4 Condition A Note CTS 3.6.5.5 ACTION (McGuire) and ACTION a (Catawba) provide the requirunents in the event that a personnel access door or equipment hatch is inoperable or open except for personnel transit entry. The CTS markup indicates that this is ITS 3.6.14 ACTION A. The Note for ITS 3.6.14 Condition A states that " separate Condition entry is allowed for each personnel access door or equipment hatch." The proposed change has been categorized as an Administrative change. This is incorrect. The wording of the CTS 3.6.5.5 ACTIONS do not indicate that a separate condition entry is allowed in the CTS, as would be allowed in the containment isolation valve CTS. In this case, if more than one access door or hatch is INOPERABLE, CTS 3.0.3 is entered. Thus, the proposed change is Less Restrictive. Comment: Revise the submittal and provide the appropriate discussion and justification for this Less Restrictive change. DEC Response: Duke Energy disagrees with this interpretation. The " separate condition entry" notes were added during development of the STS to be consistent with those cases where both the i industry and the staff agreed that separate condition entry was appropriate and permitted under the current technical specifications due to an agreement that the STS would be condition based rather than component based (refer to Westinghouse Owners Group comments on the draft STS provided to NRC July 1991). In this case, the actions are currently interpreted to allow the action time to apply to each access door or hatch individually based on the language used, i.e., "with 'a... inoperable" instead of "with one... inoperable." This is more clearly seen in the Catawba LCO which uses different language in the two actions. That is, the action for doors and hatches states "with a ... door or equipment hatch (other than one pressurizer enclosure hatch) inoperable..." and the action for the pressurizer enclosure hatch states "with one..." It is clear that the requirements are distinctly different in the existing actions. Duke Energy does not believe that the proposed ITS is less restrictive than the current licensing basis with respect to the application of this action. mc3_cr_3.6 3.6-56 March 12, 1998 1
McGuire & Catawba Improved TS Review Conments ITS Section 3.6, Containment Systems 3.6.15 Containment Recirculation Drains 3.6.15-1 DOC M.6 CTS 4.6.5.8 (McGuire Unit 2) The CTS markup of CTS 4.5.6.8 in McGuire Unit 2 shows a change cf "once per 92 days" being added. The change is designated as DOC M.6. This change does not seem to be associated with any ITS 3.6.15 item nor is it shown in the CTS markups of McGuire Unit 1 or Catawba Units 1 and 2 which have the same specification. The Justification associated with DOC M.6 is "Not used." Comment: Correct this discrepancy and provide the appropriate discussion and justification for this change. DEC Response: The McGuire unit 2 CTS markup has been revised to remove this change which is not used. o _ u o .e e.e.se es,c m 2. 1eee i J
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McGuire & Catawba Improved TS Review Comments ,f g ITS Section 3.6, Containment Systems 3.6.16 Reactor Building 3.6.16-1 DOC A.5 (ITS 1.0) CTS 1.27 ITS 3.6.16 and Associated Bases CTS 1.27 provides the definition for Reactor Building Integrity, and is justified by DOC A.5 as deleted in the CTS markup of ITS 1.0. This is incorrect. The definition is part of the Technical Specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.27 should be included in the CTS markup of ITS 3.6.16. CTS 1.27.a becomes iTS SR 3.6.16.1 (See Comment Number 3.6.16-2) and is an Administrative change. CTS 1.27.b becomes ITS LCO 3.6.10 and is an Administrative change (DOC A.1) (See Comment Number 3.6.10.1). CTS 1.27.c as a minimum would be relocated to the Bases of ITS 3.6.16 and would be a Less Restrictive (LA) change. Comment: Revise the CTS markup of ITS 3.6.16 to include an appropriate markup of CTS 1.27 and provide the appropriate discussions and justifications for these Administrative and Less Restrictive (LA) changes. See Comment Numbers 3.6.10-1 and 3.6.16-2. DEC Response: The CTS markup for ITS 3.6.16 has been revised to include CTS 1.27. Discussion of change Q M.7 was also revised to reference the CTS definition as a justification for including the new surveillance (refer to comment 3.6.16.2). Discussion of change LA.27 is added to reflect the U movement of details from the definition of reactor building integrity to the Bases for ITS 3.6.16 and the Bases are revised similar to the discussions of containment operability in STS 3.6.1. O mc3_cr_3.6 3.6-61 March 12, 1998 1
.i
, Reacter Building, >
d 3.6.16 fr , B 3.6 CONTAINMENT SYSTEMS
~B 3.6.16 Reactor Building BASES BACKGROUND' The reactor building is a concrete structure th'at surrounds the steel containment vessel. Between the containment-vessel and the reactor building inner wall is an annular space that collects containment leakage that may' occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of-the steel containment vessel.
The Annulus Ventilation System (AVS) establishes a negative pressure in the annulus between the reactor building and the steel containment vessel under post accident conditions. Filters in the system then control the release of radicactive contaminants to the environment. The reactor building is required to be OPERABLE to ensure retention of containment leakage and proper operation of the AVS. y 6L56*M , I APPLICABLE The design basis for reactor building OPERABILITY is a SAFETY ANALYSES LOCA. Maintaining reactor building OPERABILITY ensures that the release of radioactive material from the containment- 1 atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses. The reactor building satisfies Criterion 3 of 10 CFR 50.36 (Ref. 1). LCO Reactor building OPERABILITY must be maintained to ensure proper operation of the AVS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.
' APPLICABILITY Maintaining reactor building OPERABILITY prevents leakage of radioactive material from the reactor building. Radioactive
. material may enter the reactor building from the containment following a LOCA. Therefore, reactor building OPERABILITY is required in MODES 1, 2, 3, and 4 when a steam line break,
^
(continued) McGuire' Unit l' B 3.6-103 Ser b O 4ffofyf- l
l INSERT- 1 0 To ensure the retention of containment leakage within the reactor building: 1-i I
- a. Each door. in.each access opening is, closed except.when the - _
i -1 access opening is being used for normal transit entry and exit, I then at least one door shall be closed, and- I ., I {
- b. The sealing mechanism associated with each penetration (e.g.,
i. I welds, bellows, or 0-rings) is OPERABLE. -1 O
/03 INSERT Page B 3.6- I McGuire
_-- o
1 React $r BuildingL B 3.6.16 l B 3.6 CONTAIMMENT SYSTEMS 4 B 3.6.16 Reactor Building
' BASES' BACKGROUND ~ The reactor building is a concrete structure that surrounds the steel containment vessel. Between the containment vessel and the reactor building inner wall is an annular space that collects containment leakage that may occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of the steel containment vessel.
The Annulus Ventilation System (AVS) establishes a negative pressure in the annulus between the reactor building and the steel containment vessel under post accidert conditions. Filters in the system then control the relea.e of radioactive contaminants to the environment. The reactor building is required to be OPERABLE to ensure retention of. containment leakage and proper operation of the AVS. Y __
@5&f&
APPLICABLE The design basis for reactor building OPERABILITY is a SAFETY ANALYSES LOCA. Maintaining reactor building OPERABILITY ensures that the release of radicactive material from the containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses. The reactor building satisfies Criterion 3 of 10 CFR 50.36 (Ref. 1) . LCO Reactor building OPERABILITY must be maintained to ensure proper operation of the AVS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses. APPLICABILITY Maintaining reactor building OPERABILITY prevents leakage of
-radioactive material from the reactor building. Radioactive material may enter the reactor building from the containment following a LOCA. Therefore, reactor building OPERABILITY is required in MODES 1, 2, 3, and 4 when a steam line break,
[/ (continued)
~
'McGuire Unit 2 ,B 3.6-103 . JypleMJ %.s/2G/W
! INSERT I o To ensure the retention of containment leakage within the reactor building: 1 I I
- a. Each door in each access. opening is closed except when the I access opening is being used for normal transit entry and exit, I then at least one door shall be closed, and i I
- b. The sealing mechanism associated with each penetration (e.g., I welds, bellows, or 0-rings) is OPERABLE. l l
LO , 1 i lsi INSERT Page B 3.6- 1 McGuire
SPt0REAo",, M & DEFINITIONS N PROCESS CONTROL PROGRAM (PCP1 p 1.23 The PRN ESS CONTROL PROGRAM ( ) shall contain the current fomulas, sampling, analyses, test, and dete inations to be made to ensure that process-ing and packaging of solid radica ive wastes based on demonstrated processin of actual or simulated wet solid astes will be accomplished in such a way a to assure compliance with 10 CF Parts 20, 61, and 71. State regulations, burial ground requirements, an other requirements governing the disposal f solid radioactive waste. PURGE - PURGING 1.24 PURGE or PURGING all be the controlled process of dischargin air or 8ft Marbf gas from a confinement o maintain temperature, pressure, humidity, oncentra-tion or other operati g condition, in such a manner that replaceae air or b 1T3 /*0 gas is required to rify the confinement. OUADRANT POWER Til RATIO 1.25 QUADRANT ER TILT RATIO shall be the ratio of the max mum upper excore detector calib ated output to the average of the upper excor detector cali-brated output , or the ratio of the maximum lower excore de ector calibrated output to th average of the lower excore detector calibra ed outputs, which-ever is gre ter. With one excore detector inoperable, th remaining three det tors shall be used for cumputing the average. RATED T RMAL POWER
/
1.26 RATED THERMAL POWER shall be a total core heat transfer rate to the reactor coolant of 1411 MWt. _ _ q REACTOR BUILDING INTEGRITY kv / 1.27 REACTOR BUILDING INTEGRITY shall exist when: Idctuof0 Each door in each access opening is closed except when the access 1 l w sp_
. 3,4 j g ,[
@ opening is being used for nomal transit entry and exit, then at least one door s!011 be closed.
/see euch, b. The Ariptflus Vents)Ttion Syst isincompliancewiththeputrement) >
\ 4 m3.4.w ofSfecificatjpn_J.6.1.8, d
, i .
EACTOR TRIP SYSTEM RESPONSE imt Ett tvw&g Q, g g,g 1.28 The REACTOR T SYSTEM RESPONSE TINE shall be the '/.me interval from parameter exceeds its Trip Setpoint the channel sensor untti loss of ationary gripper coil voltage. (whenthemonitor McGUIRE - UNIT 1 1-5 Amendment No. 166
)
i P"JL Aa. A 3 ; l
3ff([Un'o M.1(>
~
INITIONS N PROCESS CONTROL PROGRAM (PCP) A 1.23 The PROCESS CONTROL PROGRAM PCP) shall contain the current formulas, {b} sampling, analyses, test, and de reinations to be made to ensure that process. ing and packaging of solid radi active wastes based on demonstrated processing of actual or simulated wet sol d wastes will be accomplished in such a way as to assure compliance with 10 FR Parts 20, 61, and 71. State regulations, burial ground requirements, nd other requirements governing the disposal of solid radioactive waste. PURGE - PURGING
/ Se e g, i 1.24 PURGE or PURGI shall be the controlled process of discharging air or n N gas from a confinese t to maintain temperature, pressure, humidity, concentra he 1731,o tion or other opera ing condition, in such a manner that replacement air or gas is required to purify the confinement.
OVADRANT POWER T LT RATIO 1.25 QUADRAN POWER TILT RATIO shall be the ratio of the maximum upp r excore detector cal rated output to the average of the upper excore detec r cali-brated outp s, or the ratio of the maximum lower excore detector librated output to e average of the lower excore detector calibrated out uts, which-ever is eater. With one excore detector inoperable, the resa ing three d ectors shall be used for computing the average. RATED HERMAL POWER 1.2 RATED THERMAL POWER shall be a total core heat transfer rate to the e tor coolant of 3411 MWt. } REACTOR BUILDING INTEGRITY 1.27 REACTOR BUILDING INTEGRITY shall exist when: M$% Each door in each access openin is closed except when the access
@ opening is being used for norma transit entry and exit, then at b*Y least one door shall be closed, C t h5 $ N ,[g Y"
@ Qid::""Pd:"'n '#'M.*"" "'"M"" " (* '" **'d3 rREXCT0lFTRIP SYSTEM RESPONSE TIME ~ -
Ift**ek pe @ L
\ 1.28 The REACTOR P SYSTEM RESPONSE TIME shall be the time i erval from parameter exceeds its Trip Setpoint at the .hannel sensor
[ when the monitor il loss of tionary orioper coil voltage. McGUIRE - UNIT 2 1-5 Amendment No. 148 /O V .
Disc:ssicn cf Ch:ng:s Sectirn 3.6 - Containment Systems TECHNICAI CHANGES - REMOVAL OF DETAILS described in ITS Chapter 5 " Administrative Controls." Changes to the Bases are evaluated ander the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. These changes are consistent with NUREG-1431. LA.27 CTS 1.27 items a and c define the attributes of reactor building operability and integrity. These attributes have been relocated to the Bases for ITS 3.6.16. The descriptive attributes are more appropriate information for Bases and are not necessary to be included within the Technical Specification. The requirement to maintain an operable reactor building isretained in ITS 3.6.16. The Bases are subject to the controls described in Chapter 5
" Administrative Controls" of the ITS specifications. Changes to the Bases are evaluated under the 10 CFR 50.59 criteria. Any change, using this criteria, will ensure proper review. This change is consistent with NUREG-1431.
O O McGuire Units 1 and 2 Page LA - B7 Supplement 25/20/97l
i O A Building Gua yand Ice vanoenser> 2 B 3.6.Q B 3.6 CONTAINMENT SYSTEMS
~ '
B 3.6. KBuilding tuvoi maemce toadenserb (Reule B GES g g n BACKGROUND The 6 7 M building is a concrete structure that surrounds the steel containment vessel. Between the containment vessel and the building inner wall is an annular space that collects contairnent leakage that may occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of the steel containnent vessel. y $ M " The en m ma m an a'-' i-- S stem (
) establishes a g j,,,9 b'
"" negative pressure in the annulus tween the 453E 2* building and the steel containment vesse'(. Filters in the system
~
byr /dg then control the release of rad,onctive contaminants to the environment. The storarbuilding is required to be WtMABLE cond,6,
- 6 to ensure retention of containment leakage and proper
{etu.ded operation of the p " reodor Q APPLICABLE The design basis fo SAFETY ANALYSES LOCA. Maintaining buildino OPERABILITY is a building OPERABILITY ensures that the release of radioactive material from the contairment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses. g The building satisfies Criterion 3 ofh MRC Pn MrD G W (loCAG40*36.llefh ph
#5 LCO % building OPERABILITY must be maintained to ensura GH proper operation of the and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.
CnS APPLICABILITY Maintaining GIETi 11 ding OPERABILI prevents leakage of radioactive materia from the 11 ding. Radioactive material rey enter the buildi from the containment following a LOCA. Therefore, uilding OPERABILITY is required in MODES 1. 2, 3 and 4 when a steam line break, (continued) 10G ST5 8 3.6-180 Rev 1, 04/07/95 O &u.o V
INSERT I O To ensure the retentfion.of containment leakage within the reactor building: l i i
- a. Each door in each access opening is closed except when the i access opening is being used for normal transit entry and. exit, I then at least one door shall be closed, and I l
- b. The sealing mechanism associated with each penetration (e.g., I welds, bellows, or 0-rings) is OPERABLE. I O
INSERT Page L 3.6-180- , A-Q NcGuire i 1
McGuire & Catawba Improved TS Iteview Comments ITS Section 3.6, Containment Systems O 3.6.16-2 DOC A.5 (Section 1.0) DOC M.7 JFD 3 - JFD Bases 2 JFD Base 3 CTS 1.27.a STS SR 3.6.1.9.2 ITS SR 3.6.16.1 and Associated Bases CTS 1.27 provides the definition for Reactor Building Integrity and is justified by DOC A.5 as deleted in the CTS markup of ITS 1.0. This is incorrect. The definition is part of the technical specifications and as such delineates CTS requirements. Therefore an appropriate markup of CTS 1.27 should be included in CTS markup of ITS 3.6.16 (See Comment Number 3.6.16-1). CTS 1.27.a is the same requirement and used basically the same words as STS SR 3.6.19.2. Therefore the addition of ITS SR 3.6.16.1 is not a More Restrictive change but an Administrative change. .The addition of the frequency of 31 days is however, a More Restrictive change. In addition, STS SR 3.6.19.2 requires verifying that each door in each access opening is closed, except when the access opening is being used for normal entry and exit; "then, at least one door shall be closed". ITS SR 3.6.16.1 deletes the phrase "then, at least one door shall be closed" based on the JFD 3 which states that this requirement is not applicable to the facility. The Bases for ITS SR 3.6.16.1 also deletes this requi.rement. This O is incorrect since CTS 1.27.a has these words. Comment: Revise the CTS markup according to the above discussion (See Comment Number 3.6.10-1), delete the change to ITS SR 3.6.16.1 and its Associated Bases that deletes the phrase *then, at least one door shall be closed," and provide any additional discussions and justifications to support these required changes. DEC Response: Discussion of change M.7 has been revised to reflect that the new surveillance is consistent with the existing definition for reactor building integrl'/. The definition is added to the markup for ITS 3.6.16 as an A.1 change (refer to comment 3.6.16-1). The ITS SR and associated Bases are revised consistent with the CTS definition and the STS.
'mc3_cr_3.6 3.6-62 March 12, 1998
Reactor Building 3.6.16 3.6 , CONTAINMENT SYSTEMS 3.6.16 Reactor Building LCO 3.6.16 The reactor building shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor building A.1 Restore reactor 24 hours inoperable. building to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion (O %) Time not met. AND 8.2 Be in MODE 5. 36 hours SURVEILLAACE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.16.1 Verify each door in each access opening is 31 days closed, except when the access opening is being used for normal transi_t entry and
**I g) ][,sf one.
4,il h Lt. c1*SfD /
~
(continued) .rx V McGuire Unit 1 3.6-40 SW/bd 3720/9/ ~
Reactor Building 3.6.16 3.6 ' CONTAINMENT SYSTEMS ! 3.6.16 Reactor Building LCO 3.6.16 The reactor. building shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION. COMPLETION TIME A. Reactor building A.1 Restore reactor 24 hours inoperable. building to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AliQ B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.16.1 Verify each door in each access opening is 31 days closed, except when the access opening is being used for normal transit entry and-b atl<md one, be sbli k d.u ; (continued) O McGuire Unit 2. 3.6-40 SufpkNdL 5#0/9T-
a R: actor Building B'3.6.16
~\
.,,-~ BASES APPLICABILITY- LOCA, or rod ejection accident could release radioactive (continued) material to the containment atmosphere. In MODES 5 and 6,.the probability and consequences of these events are low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, reactor ; building OPERABILITY is not required in MODE 5 or 6. j ACTIONS 6.d In the event reactor building OPERABILITY is not maintained, reactor building OPERABILITY must be restored within 24 hours. Twenty-four hours is a reasonable Completion Time considering the limited. leakage design of containment and the low probability of a Design Basis Accident occurring during this time period. B.1 and B.2 If the reactor building cannot be restored to OPERABLE O) N. status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conriitions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.16.1 REQUIREMENTS Maintaining reactor building OPERABILITY requires maintaining each door in the access opening closed,'except when the access opening is being used for normal transit (h MNp entry and exitY The 31 day Frequency of this SR is based on g h.argggpock engineering judgment and is considered adequate in view of the other indications of door status that are available to the operator. (continued)
- McGuire Unit 1 B 3.6-104 J Upp W L 5/20/97 --
Reactor Building 8 3.6.16' BASES
' APPLICABILITY LOCA, or rod ejection accident could release radioactive.
. (continued) material to the containment atmosphere.
In MODES 5 and 6, the probability and consequences of these events are low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, reactor building OPERABILITY is not required in MODE 5 or 6. ACTIONS L1 In the event reactor building OPERABILITY is not maintained, reactor building OPERABILITY must be restored within 24 hours. Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probability of a Design Basis Accident occurring during this time period. B.1 and B.2 O If the reactor building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.16.1 REQUIREMENTS Maintaining reactor building OPERABILITY requires maintaining each door in the access opening closed, except (b 4 lcas}. when the access opening is being used for nonnal transit entry and exitt The 31 day Frequency of this SR is based on
,4 4., y .
engineering judgment and is considered adequate in view of
" Cbh the other indications of door status that are available to the operator.
1 (continued) McGuire Unit 2' B 3.6-104 Ivpphad 2.,j20/W i
r-Specification 3.6. l(, O' INSERT 14 CONDITION REQUIRED ACTION COMPLETION TIME-B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours INSERT 15 M. O SR 3.6.16.1 Verify each door in each access opening 31 days is closed, except when the access opening is being used for normal transit entry and exit; then, at least one door shalI be closed. i
-i McGuire Page2 of 3 l
' Specification 3.6'.'Ib O INSERT 14' CONDITION REQUIRED ACTION COMPLETION TIME iB. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion
. Time not met. ANJ B.2 Be in MODE 5. 36 hours INSF.RT 15 A.7 O
SR 3.6.16.1 Verify each door in each access opening 31 days is closed, except when the access opening is being used for normal transit entry and exit; then, ot least one door shali be closed.
- -McGuire, Page T of 3 o
Discussicn of Ch:ngis Section 3.6 - Cintcinment Systems TECHNICAL CHANGES - MORE RESTRICTIVE M.5 Not used. M.6 Not used. M.7 An additional surveillance is proposed for CTS 3.6.1.7 to verify each door in each access opening to the reactor building is closed, except when the access opening is being used for normal transit entry and exit. This additional surveillance is acceptable because the integrity of the reactor building is important to the dose calculations following a DBA and it is required by CTS 1.27.o. This change is considered more restrictive because it requires additional surveillance beyond that which are presently performed for the reactor building integrity. This change, retained in ITS 3.6.16, is consistent with NUREG-1431. M.8 CTS 3.6.4.3 Actions provide actions for inoperable hydrogen igniters. If these actions con not be satisfied, CTS LCO 3.0.3 must be entered which requires action within 1 hour or a shutdown to MODE 3 in the following 6 hours. ITS 3.6.9 requires that if these some actions cannot be met the plant must be placed in MODE J 3 within 6 hours. This change is slightly more restrictive since the CTS would provide 1 additional hour. This change is acceptable because it places the plant in a MODE where the specification is not applicable. This change is consistent with NUREG-1431.Not =cd. M. 9 CTS 4. 6. 5. 3.2. 0 requires verifying that the intermediate deck doors are free of frost accumulatton. ITS SR 3.6.13.2 requires verifying that the doors are not impaired by ice, frost, or debris. This requirement is more restrictive than the current stated requirements, however, it is consistent with existing operating practices and with NUREG-1431. q
]
McGuire Units 1 and 2 Page M - 23 Supplement 25/20/97l _-___-______-____________N
Building ma i narf ice Cnnrien#r9 g
' *% v SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6. Verify each door in each access opening is 31 days closed, except when the access opening is . bei used for normal d7EneHE1;rentry ana - "' erit ; en. at innst one ooor snpii pe) I os 4g SR 3.6. wN
.F Verifv dMTb building structural integrity 40 me fli Auo l
by performTng a visual inspection of the shutdown for yu j h, atvub exposed interior and exterior surfaces of SR 3.F.1.1 % the building. Type A tests . l
@ (diMudsS Venh(*fror0 (4)
SR 3.6.9 Verify each ani 'uf su, mian o r C6-w, 118)'monthson l System train 6fm imm i t t== < i # cts a STAGGERED
.produc q a pressure equal'to or more negative than X-0.51 inch water gauge in TEST BASIS @
g the annulus within f221 seconds after a start signa . and -3.6 inchep <seler 4 sigt affe+- Af seconds. Utv;Q SJ wpon redq + nep% p<'s u t of ~3.5 inch *$ wn}ev pc, in (.he annaly ,fAe 69 4/ce Adches Info <YS rectrealafe,h
> .lc. el opeenkok And ki- t'bst .
L w t., ve qtu r b d b b e a>1ns k p prc%uve. k for4W. So - 0 6 ech Jeg 85 2 2# seconds j l l
= 20 3.6-65 Rev 1. 04/07/95 Mc GuerL l /m .
E i GEDihP Building (6iai sad Ica <~m g 83.6.8g y BASES SURVEILLANCE REQUIREMENTS SR 3.6. @@
/
(continued) Maintaining attmralDbu11 ding OPERABILITY requires maintaining each door in the access opening closed, except when the access opening is being used for normal C anatSizftntry 'QQ ' f h vn.,r .,
<---.-,mo.- - ,-. . _ ; ,, c . . - 3 The' I day frequency of this SR is based on engineering j j 5768 and is considered adequate in view of the other indications of door status that are available to the operator.
SR 3.6. 3 M C" This SR would give advance indication of gross deterioration )( Qi 5 (4o,.50 ' of the concrete structural integrity of the building. TheTFrequency 6t this a u cne same n r-rr av w 3.54.TL ll Lahd ** 44' rre,v;<- c3 L The verificati_onjis done during shutdown.
' Spec
.9 = n f twe ( ,,4c,e e is .fe A gre A
- A n$w e (e ., ,
- SR 3.6.
i The ability of a Avt A train ME Mnamow se i cidDt L m hl - O 4 y 5fti.b.l.g #,"g'}j ea l o .gcer ed'* - / J produce the required negative pressure o + --~ - - within E --- ~provides assurance that the building is adequately sealed. The negative pressure prevents leakage from the building, since L outside air will be drawn in by the low pressure. The nogetive pressure sust be established within the time limit to ensure that no significant quantity of radioactive material leaks from the building prior to developing 4 the negati re sure, c gg The rai are tested every 18 months on a STAGGERED i l/m/s/drad TEST BASIS to ensure that in addition to the reauirements of3
@ LCD 3.6.5, *-- A i M - - 2- - ~5ystem," either train will perform this test. The 18 month Frequency
@is based on the need to perfom this Surveillance under the
@ conditions that app 1" Jaring a plant outage.
REFERENCES W
- N '50 545 Sye,/.dwfeXt h h 4Grr4Hr , B 3.6-182 Rev 1. 04/07/95 14e (eac. w C
[') u ~ 4
McGuire & Catawba Improved TS Review Comments ITS Section 3.6. Containment Systems 3.6.16-4 DOC A.35 CTS 4.6.1.7 ITS SR 3.6.16.2 and Associated Bases CTS 4.6.1.7 for McGuire is converted to ITS SR 3.6.16.2. Based on the Writers Guide with regards to SR order, this SR should be SR 3.6.16.3 as was done on the Catawba ITS. Comment: Renumber the SRs in accordance with the Writer's Guide and revise and update DOC A.35 to conform to the new numbering. DEC Response: The McGuire ITS, CTS markup, and STS markup have been revised to reorder the surveillances consistent with the Catawba ITS and the writer's guide. O ( mc3_cr_3.6 3.6-64 March 12, 1998
I R:acter Building 3.6.16 o
^
SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY l SR 3.6.16.[) Verify reactor building structural 40 months ' integrity by perfonning a visual inspection of the exposed interior and exterior N[Q surfaces of the reactor building. During shutdown for SR 3.6.1.1 Type A tests SR 3.6.16. Verify each Annulus Ventilation System 18 months on a train produces a pressure equal to or more STAGGERED TEST negative than -0.5 inch water gauge in the BASIS annulus within 22 seconds after a start signal and -3.5 inches water gauge after 48 seconds. Verifying that upon reaching a negative pressure of -3.5 inches water gauge in the annulus, the system switches into its recirculation mode of operation and that the time required for the annulus pressure to increase to -0.5 inch water gauge is :t 278 seconds. G t McGuire Unit 1 3.6-41 Svff k#AdL _.5/sef97--
R acter Building
,- 3.6.16 d' SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.16. Verify reactor building structural - 40 nonths integrity by perfonning a visual inspection of the exposed interior and exterior Atul surfaces of the reactor building. During shutdown
] for SR 3.6.1.1 Type A tests SR 3.6.16. Verify each Annulus Ventilation System 18 months'on a
{ train produces a pressure equal to or more STAGGERED TEST
\
negative than -0.5 inch water gauge in the BASIS annulus within 22 seconds after a start signal and -3.5 inches water gauge after 48 seconds. Verifying that upon reaching a ( negative pressure of -3.5 inches water
\ gauge in the annulus, the system switches into its recirculation mode of operation and that the time required for the annulus pressure to increase to -0.5 inch water gauge is 1 278 seconds.
O faf[bmd2-McGuire Unit 2 3.6-41 5/20/9T~
R: actor Building B 3.6.16 i C ' BASES SURVEILLANCE SR 3.6.16.' l REQUIREMENTS (continued) This SR would give advance indication of gross deterioration of the concrete structural integrity of the reactor building. The 40 month Frequency is based on the requirement to perform two additional inspections at approximately equal intervals between the Type A tests required by SR 3.6.1.1 performed on a 10-year interval. The verification is done during shutdown.
$R 3.6.16.O The ability of a AVS train to produce the required negative pressure within the required times provides assurance that the building is adequately sealed. The negative pressure prevents leakage from the building, since outside air will be drawn in by the low pressure. The negative pressure must be established within the time limit to ensure that no significant quantity of radioactive material leaks from the
- reactor building prior to developing the negative pressure.
O The AVS trains are tested every 18 months on a STAGGERED TEST BASIS to ensure that in addition to the requirements of LCO 3.6.10, " Annulus Ventilation System," either AVS train will perform this test. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. REFERENCES 1. 10 CFR 50.36 Technical Specifications, (c)(2)(ii). E LMcGuire Unit 1 8 3.6-105 8vf/ 4/e0/97-l,
R actor Building B 3.6.16 BASES SURVEILLANCE I SR 3.6.16 [ 3 REQUIREMENTS (continued) This SR would give advance indication of. gross deterioration of the concrete structural integrity of the reactor building. The 40 month Frequency is based on the requirement to perform two additional inspections at approximately equal intervals between the Type A tests required by SR 3.6.1.1 perfonned on a 10-year interval. The verification is done during shutdown. SR 3.6.16.Y7-The ability of a AVS train to produce the required negative pressure within the required times provides assurance that the building is adequately sealed. The negative pressure f prevents leakage from the building, since outside air will be drawn in by the low pressure. The negative pressure must be established within the time limit to ensure that no significant quantity of radioactive material leaks from the reactor building prior to developing the negative pressure. The AVS trains are tested every 18 months on a STAGGERED O TEST BASIS to ensure that in addition to the requirements of LCO 3.6.10 " Annulus Ventilation System," either AVS train will perform this test. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. REFERENCES 1. 10 CFR 50.36. Technical Specifications, (c)(2)(ii). q
)
McGuire Unit 2 B 3.6-105 Spludd 2 .5#0/;7 -
, Ger:Sct$n 3.fo.14 CONTAINMENT SYSTEMS
@AEACTOR BUILDING (fRue16ItAFkT&,
(fiNdC0 DON FOR DPETATIOD
~ -
g,f 4 c.0 3.6 ~ Q5E4'4BLE) The EtsacCurakiliteerRiTafA GD reactor building shall bfmytfital C'5FeveJ4onstsJent anyme .wr.a nce/,r1tertap spe5>ncatyt sr4.6 .. I APPLICABILITY: M00E3 1, 2, 3, and 4. . gligg: uYh Ab I.
##"#ar537ta @f%nr*.#f1'C?##$$lii'i,I" i J !!;'$in'Mef')
f, .1-, ing tnwer Coo.lanesystem; . .. 61,
.p3s
/A" '4 W 8^
$URVEILUUICE REOUfREMENTS WNmJVAnak jy;sgrt/S GA' 9.L 16 1 .
se S.4g, 3 - The structural integrity of the reactor butiding shall be determined during the shutdoun for each Type A containment leakage rate test l specification arEEM by a visual inspection of ible the exposed6 ac
@64.II/h interior and exterior surfaces of the reactor butiding/anagertf ng 4ND Mrems ' d l.. in Mradatta. -- -eer.a f the Type A ei aiw wm.wse suryaces or et 1
( ' asett4onalWspections snal t is ormed pt lo-yfar inDervals, two perf at Approxigately/equaVinte is ivride shutdhuns he+.A T A tes y ab I rada on o sne i act v butidied detect duri the m e re i t ss 11 hel ( reporfedtotlydCommis on pu tt 10 CFR i 50. .a 50.73.) 4 5p O I McGUIRE - UNIT 1 3/4 6-10 Amendment No.173
- g. /of .5
5= 6* l$*
$)lRe4kt's.bwr1
. CONTAlifGT SYSTBE5
.i
'lURVEILlaawv agggtaggTS (Centinmed) f
- c. After every F20 heers of charcoal adsorber operation, by verifying within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with negulatory post- ;
tien C.E.h of latory Guide 1.52. Revision 2. March 1978, and tested per ASTM 3-8g. has a methyl iodide penetration of less e paartaf #(' d.
""*" "%3 At least once per 18 neaths, by:
9tdd/d
- ),(e, flP)
I
- 1) Verifying that the pressure drop across the ceabined IEpA ;
filters and charcoal adsorber banks is less than 6 inches Water
/_ ,2 Gauge dile operating the system at a flow rate of 8000 cfm a 10%; ,
- 2) Verifying that the systen starts automatically en any phase 8
] l{
6Thimla WOj tseletten test signalg
- 3) Verifying that the filter cooling electrir motor-eee ygH;r 8 @ $J breass valves can be we e rs veaktaJro.D -
e _r-g g, y, (,, //,, ) $ verifying that eachhenfeduces a negative pressere of greater t er equal to 0.5 inch W.G. In the annulus within zz seconds after a start signal and that this negative pressere te -3.5 inches W.G. within 48 seconds after the start si 1. Verifying that upon reaching a negative pressues of -3.5 oches W.G. In the annoiss. the system switches inte its recirculation mode of operetten and that the time required for the annules pressere te lacrease te -0.5 inch W.G. is gewater than er equal to 278 secondst
- 5) ~ vert snet the pre-heaters dissipate 43.0 a 5.4 lef at a t. #" Y meetna voltage of 600 VAC d en tested in accordance with Spcadsca. dea AlI51 N510-1975. g, g ,g '
After each cesplete er partial replacenset of a HEpA filter bank, by I
- e. I verifying that the HEpA filter bank satisfies the in-place penetre-tien and bypass leakage testing acceptance criteria of less than 14 in accordance with AlI51 N510-1975 for 00p test aerosol dile j sperating the systen at a flew rate of SC80 cfm a 10%; and f
- f. After r,ach cesplete er partial replacement of a charcoal adseriwr bank, by verifying that the charcoal adsorter satisfies the in-place k penetration and bypass leakage testing acceptance criteria of less I than 14 in accordance with AftSI 11510-1975 for a halogenated hydro-carten refrigerant test gas elle operating the systen at a flew rate of 8000 cfm a 10%.
[ nceutaE - UNIT 1 3/4 6-12 Assadment No. 156
%e 3 43 4
, sp e d a % .r.6. a h CONTArmeENT SYSTEMS MREACTOR BUILDING STRUCTURAL INTEGRITY (LInsitG canaH1f0N F&0
~
compatr5 t,c o 3.6 The ftrettucePfateefftwsfiD reactor bu ta (atreveteststw wunp -yescysery,ll' ding shall n y,m 4.6. APPLICA8ILITY: MODES 1, 2, 3, and 4. gg snet %2 w <, n, . J%
%:,n,!!d:rP*% --
6
, .#. ,3. ::::'PC:"/ cst,u 2:iif.Mf'to "
L260f
.s, _ 7 . wstem te.,.rm,e a.,e
,. _#d';
U?10SOfM h 4ch8k'8/ SURVEILLANCE REOUIREMENTS Q1%;r MAewn l'EI
. J Q M O'l & & % 5 4 J6a/
y -u .t6, The structural integrity of_the reactor building shall be determined ng the shutdown for each Type A containment leakage rate test ;
- 0 * /' I SpecificationcsJwP.D by a visual inspection of the exposed access (iblereferwace #88'"
taterior and exter or surfaces of the reactor buildine/ana yartfyf s
, 7.gi, dd'O 44./ ldefradat . n - -'-=== owe menerwr-ersaces orother~
real tvpe A test is perfetted at N-year intervals, taRr 3g fdurine
.. euenshutdowns
~
v1acettional between Type Ashall inspections testsbe / any _ ___. i at approxima performed 6ne reactor asilaing setecten ouw ng the above required inspections shall be - rted to tiie Commission pursuant to 10 CFR Sections 50.72, and 50.73. O d e McGUIRE - UNIT 2 3/4 6-10 Amendment No. 155 e lD? .h
3-(s. ((p Q u.NiebbH
^itsanre u . _,, fr eq- m /j,l
- c. After every 720 hours of charcoal adsorber operetten. by veri
- withia 31 days after renewal that a laboratory analysis of a rupre-sestative corben saeple obtataed in accordance with Regelatory post-tien C.6.b of latory Guide 1.52. Arvision 2. North 1978, and /
\gCg. Y g tested per A51N 3-43, has a methyl fedide penetration of less thee 44; SpfddcAfW6
- d. At least esce per 18 months, by:
- 1) Verifyfag that the pressere drop across the codined IEpA filters and charcoal adsorber beaks is less than 5 laches Water 0% Gauge dile operating the system at a flew rate of 4000 cfm a
//assed% an E. 10%;
$g 2) Verifying that the systes starts automatically en any phase S Isoletten test signal;
- 3) verifylag that the filter cooling electric ester eperated _
. bypees valves can be seemed; , _[j,,,,a
#4 5.(<. //, S VerifytagW eachfhepredeces a ascetive pressure of l prester them er equel to 4.5 inch M.G. in the amaulus within Er seconds after a start signal and that this negative pressure te -3.5 faches W.G. withis 48 secamer after the start si . Verifying that spes reading a negative pewssure of -3.5 sches W.E. to the aansles, the systes switches inte its recirculation made of operation and that the time required for the annales pressere to facrease to -0.5 inch W.G. is greater then er ogeel to ZF8 seceeds;
^
- 5) Verifly us .
b VAC d en tested la accordance with-- 5=s dissipate 43.0 a 5.4 kW a meslest vel AN5! A510-1 g of
- e. After each eseplete er partial ruplacement of a NEpA filter bank, by verifying that the NEpA filter bank satisfies the in-place penetre.
$8yQfe ties and typass leakage testing acceptance criteria of less than 14 5./a.10) l is accordance with ANSI N516 1575 for 00p test aerosel dile eperatieg the system at a fler reta of 3000 cfm a let; and
- f. After and complete er partial replacement of a charcoal adsorter beak, by verifying that the cherceal adsorber satisfies the fe-place penetretten and hypass leakage testing acceptance criteria of less then 14 is accordance with ANSI A510-Ig?5 for a halogenated hydro-cartes refrigerunt test pas dile operating the system at a flew j
)
rete of 0000 cfm
- 104.
McWIK - ut!T 2 3/4 6-12 Amenteent me. 148 h '" O ; t_
Discussien cf Ch:ngIs Section 3.6 - CcntSinment Systems O ADMINISTRATIVE CHANGES V entering CTS LC0 3.0.3, this change is considered administrative. This change is consistent with NUREG-1431. A.33 Not used. A.34 The requirements in CTS 4.6.1.2.f for bypass leakage testing on a 24 month basis during applicable types B and C testing has been revised. The frequency in ITS SR 3.6.3.87 is in accordance with l 10 CFR 50 Appendix J, as modified by approved exemptions. The proposed change is considered administrative since 10 CFR 50 Appendix J establishes a maximum interval of 24 months for types B and C testing, therefore, the existing requirement is maintained. This change is consistent with NUREG-1431. A.35 CTS 3.6.1.7 requires the structural integrity of the reactor building be determined during the shutdown for each Type A containment leakage rate test or if the Type A test is performed at 10 year intervals, two additional inspections shall be performed at approximately equal intervals during shutdowns between Type A tests. Since the station performs Type A tests every 10 years the frequency of 40 months was established since it O< is equivalent to one inspection performed every 10 years and two other inspections performed at equal intervals within that 10 years. This change, retained in ITS SR 3.6.16.33, is considered l administrative since it does not change the present intervals for inspection. A.36 Not Used. A.37 CTS 4.6.4.3.a requires that 32 of 33 hydrogen igniters be operable on each train. ITS SR 3.6.9.1 requires 34 igniters per train to be operable. The actual design contains 35 igniters per train. This change simply corrects an inadvertent error in the CTS. The number of igniters was increased as discussed in SER Supplement 7, Attachment C, after the first refueling outage of each unit. This change corrects the TS with the approved licensing basis as described in the SER supplement. A.38 CTS 3.6.1.2.c and 4.6.1.2.f specifies requirements for reactor building bypass leakage limits. These requirements and associated actions and surveillance requirements are combined with the McGuire Units 1 and 2 Page A - 97 Supplement 25/20/97l
Disc 2ssion cf Ch:nges S:ctien 3.6 - C:st inment Systems TECHNICAL CHANGES - LESS RESTRICTIVE acceptable because it does not change the frequency of the surveillance on a component basis, but provides flexibility as to when it can be done. In addition, eliminating the STAGGERED TEST BASIS requirement will limit the number of containment entries and therefore radiation doses since surveillance performance requires containment entry. This change is considered less restrictive because it allows flexibility in the timing of these surveillance tests. This change is consistent with NUREG-1431. L.21 CTS 3.6.1.7 requires the structural integrity of the reactor building be met prior to increasing the Reactor Coolant System temperature above 200 'F. The CTS does not address the required actions if the reactor building structural integrity is found not met when in MODES 1 through 4 (the MODES of applicability), requiring LC0 3.0.3 be entered. ITS 3.6.16 allows 24 hours to restore the reactor building to OPERABLE status before having to shut down. The 24 hours is based on the limited leakage design of containment and the low probability of a DBA occurring during this time period. This additional time is acceptable because it does N not impact the health and safety of the public. This change is considered less restrictive because more time at power is allowed with a reactor building inoperable. This change is consistent with NUREG-1431. L.22 CTS 4.6.1.8.d.4 requires the negative pressure in the annulus be verified during the operation of each Annulus Ventilation System (AVS) once per 18 months. ITS SR 3.6.16.23 performs this l surveillance every 18 months on a STAGGERED TEST BASIS. This change is acceptable because the AVS is tested every 18 months via the Ventilation Filter Test Program (VFTP) in ITS 3.6.10. The test being performed in ITS SR 3.6.16.23 is for the reactor l building integrity. It does not matter which AVS is used to perfonn this test since either one will provide the appropriate flow. The end result is that the reactor building integrity will continue to be tested every 18 months but a different AVS train will be used each time. This change is considered less restrictive because this test was performed twice (once per train) every 18 months since it was combined with each AVS train test but will now only be required once every 18 months. This change is consistent with NUREG-1431. I ( McGuire Units 1 and 2 Page L - 740 Supplement 25/20/97l
N3 Significtnt NIz:rds C!nsidirstian Sscticn 3.6 - Cantninment Systems LESS RESTRICTIVE CHANGE L.22 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431 " Standard Technical Specifications Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive. Below is the description of this.less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431. CTS 4.6.1.8.d.4 requires the negative pressure in the annulus be verified during the operation of each Annulus Ventilation System (AVS) once per 18 months. ITS SR 3.6.16.23 performs this surveillance every 18 months on a l STAGGERED TEST BASIS. This change is acceptable because the AVS is tested every 18 months via the Ventilation Filter Test Program (VFTP) in ITS 3.6.10. The test being performed in ITS SR 3.6.16.23 is for the reactor building integrity. l It does not matter which AVS is used to perform this test since either one will provide the appropriate flow. The end result is that the reactor building integrity will continue to be tested every 18 months but a different AVS train will be used each time. This change is considered less O restrictive because this test was performed twice (once per train) every 18 months since it was combined with each AVS train test but will now only be required once every 18 months. This change is consistent with NUREG-1431. In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.
- 1. Does the change involve a significant increase In the probability or consequence of an accident previously evaluated?
The proposed change only requires one negative pressure test of the reactor building every 18 months instead of the two required by the CTS. An inoperable reactor building is not assumed to be the initiator of any analyzed event, therefore, the change does not affect the probability of an accident. The change will not alter assumptions relative to the mitigation of an accident or transient event. Due to the limited leakage design of containment the change will not involve a significant increase in the O consequence of an accident previously evaluated. McGuire Units 1 and'2 Page 4561 of 6161 Supplement 25/20/97l
i - Building tthm i =< ic_, canciensen g 3 6 ats> u ( SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 9 Verify each door in each access opening is 31 days l SR 3.6.8.1 O/, closed, except when the access opening is - bei d for nonaal drnnsmmtrentry ano . g**,.9
, g {
exit . at iean one unor sryti nej W
-- n, g D SR3.6.5.y city during
=Vo m. Auo Q l a Ver
- B Til abuildink by perforiTng structural visua inspection of t inteke shutdown for a J )'
')*, exposed interior and exterior surfaces of SR 3.F.1.1 % l tt*M the afftFr5 building. Type A tests t i I
~ _.
i (4* ret [5 Ve*16/atfrM h SR 3.6.pg wgr ;fy y ~each meld aus imnerlir_Usanop,$18)'sonths on l C# n em train 6 fin sanai tims < l #ctap a STAGGERED
~
. produce $ a pressure equal to or rnore negative than X-0.51. inch water gauge in TEST BASIS h the annulus within 1221 seconds after a start r,igna .
l ' l a>ut ~3.6 inches wier gqt-
&<r Ag stone. Osv.CA :
l W1 wfon wam+mais pc%uae, 4 -3.'s anche$ wdes- @ i i y.ugc, oh Oc ana$ ,0c SQW Swdekes Mle *YS **ccercula]tek l d ,lc. 4 op6toh and Sd- tac f 4,imo giudd h Me 4Andus l prewsc. b twenc. b - e.6 mch 1 i (J.geS'zZWReondS ) l l
-E STL 3.6-65 Rev 1. 04/07/95 j Nc GatW l n i i
t i
~
O am EUdhP Building (Dua i End Ic, rmwr; g B 3.6.g y aASES SURVEILLANCE RE IREMENTS SR 3.6. Qh continued) Maintaining building OPERABILITY requires maintaining each door in the access opening closed, except when the (by,g@ access opening is being used for normal franuetDrentry an ex t<marv a+ - ' '~- ana r = = er oGD. The 56 ay Frequency of this SR is based on engineering ,fudgnen and is considered adequate in view of the other indications of door status that are available to the operator. SR 3.6. & M C This SR would give advance indication of ross deterioration )( Qi 5 building. (4 o n.' 50 ',ThAFrequency of the concretebi this dN ustructural cne 5ame at u integrity o1 SH 3.6d . h.of t0e II La1*2 % de tr$vWJ1 The verification)is done during shutdown. b ep $en k o)) L 1 7 Q ,Q In'$ptc44 J of appa,' l' Fr ue l el4fe r a ls fe bt.ee, SR 3.6.9
)- h A mr h f w ryyeA 404requin The ability of a train 41tii KnaLMow rni cMDto g 4 produce the required negative pressure a m C A - i -
V y5fLI.bl.g#feg'}j o.1 a lo.je.cedfew - gm su mg t;a- : .. _. _; ;,- within #71 - -frovides assurance that the building is adequately sealed. t negative pressure revents leakage from the buildi , since outside air will b drawn in the low pressure, e negative pressure asst be est lished within the time limit to ensure that no significant quantity of radioactive seterial leaks from the building prior to developing 4 the negat ure, t 4g The ns are tested every 18 months on a STAGGERED i l/m/ddroA TEST BASIS to ensure that in addition to the requirements of) - b LW 3.6. O. *in w a A i kino air E --- 35ystem," either train will perform this test. The 18 renth Frequency
@is based on the need to perfona this Surveillance under the .
@ conditions that app 1" J.aring a plant outage.
REFERENCES D M M 60 43 Spul afeXth B 3.6-182 Rev 1, 04/07/95 410G-ST& . Me 6r.c& C O f 1 j I l
I McGuire & Catawba Improved T5 Review Comments ITS Section 3.6, Containment Systems q O ~ CTS 3/4.6.4.1 Hydrogen MonRors 3/4.6.4.1-1 DOC - None CTS 3/4.6.4.1 The markup for CTS 3/4.6.4.1
- Hydrogen Monitors" shows that this specification is to be relocated to ITS 3.3.3. No justification is provided for this Administrative change. Comment:
Provide a discussion and justification for this Administrativo change. DEC Response: The CTS markup is revised to show the movement of this requirement to another section as a DOC A.1 change. O o d mc3_cr_3.6 3.6-69 March 12, 1998
crs Wq.c.4 O' CONTAIMDIT SYSTDIS 3/4.6.4 Ca stisTIGLE GAS CONTROL MVOA0 GEN [WNITOR$
~
LlellTING enunifl0N FOR OP0tATION f 3.6.4.1 Two independent containnent hydewgen monitors shall be.0PERA8tE. APELICASILITY: M00E3 1 and 2. ACTION: With one hydrogen monitor inoperable, restore the inoperable monitor to OPDIASLE status within 30 days or be in at least NOT STAND 8Y within the next 6 hours. SIRVEltlamer arautRDGITS 4.6.4.1 Each hydrogen monitor shall be demonstrated OPDIABLE by the performance of a OWelEL CHECK at least once per 12 hours, an AllALOG CHAMEL OPDIATIONAL TEST at least once per 31 days, and at least once per g2 days on a STAGGUIED TEST BASIS by perforslag a CHAlelEL CALIBRATION esing hydrogen gas sixtures to obtain calibration pstats of:
- a. Zero volume percent hydrogen, and
- b. Nine volume percent hydrwgen. -
1 I
-o e) A.
.n s.vs
. I 3/46-17 Amendment 110. 166 ledlWIRE - INIIT 1 O .
g,, ,s ,
E cnuranmarr systes , O63/g ,/,. $ 3/4.6.4 CamlSTraLE GA5 ColmWL HVIIA0 Gell ISIITOR$ tintrIns =rften Far OPERATICII \
\
.3.6 4 1 Two fi;"- t contalement hydrogen monitors shall be OPDtABLE. {
I APPLICABILITY: IIDDES 1 and 2. ACIlWl ., k, - With one hydrepen mentter inoperable, restere the inoperable mentter to OPERABLE status withis 30 days or be is at least HDT stale 8Y withis the next 6 hours. . SIEVf1LLar E asaut m , 4.6.4.1 Each hyd maatter shall be demonstrated OPSIABLE by the ormance of a OIECK at least once per 12 hours, an Afl4 LOG OIAffs. TIGRAL TEST at least once per 31 days, and at least once per 92 days en a STamassen TE3T BASIS perf a OIAllllEL CAllSRATIOli using hydrogen gas sisturew to obtata cal ration pe ats of:
- a. Zero volume percent hydrogen, and'
- b. Nine volme percent hydrogen.
u6 6 p e J a b o h 3 5. s } ,', l MceUIRE ISIIT 2 3/46-17 Amendment flo. 144 , O
O ENCLOSURE 2 ITS SPECIFICATIONS AND BASES FOR SECTION 3.6 O l O l
-- )
1
,- Centainment 3.6.1 -
3.6 ' CONTAINMENT SYSTEMS 7-) V 3.6.1 Containment-LCO 3.6.1 Containment shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
' CONDITION REQUIRED ACTION COMPLETION TIME
'A.
Containment A.1 Restore containment I hour inoperable. to OPERABLE status. B. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion Time not met. Alm B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SUP.VEILLANCE FREQUENCY SR 3.6.1.1 --------------------NOTE------------------ The space between each dual ply bellows assembly on penetrations between the containment building and annulus shall be
. vented to the annulus during Type A tests.
Perform required visual examinations and In accordance Type A' leakage rate testing in accordance with the l with the Containment Leakage Rate Testing Containment , Program. Leakage Rate Testing Program (continued) J [ .McGuire Unit 1 3.6-1 Supplement 2 l
Centainment 3.6.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.1.2 --------------------NOTE------------------
- 1. Following each Type A test, the. space between each dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig' to verify no detectable leakage, or the assembly shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa.
- 2. Type C tests on penetrations M372 and M373 may be performed without draining the glycol-water mixture from the seats of their diaphragm valves if -----NOTE------
meeting a zero indicated leakage rate SR 3.0.2 is not (not including instrument error). applicable Perform required Type B and C leakage rate In accordance testing, except for containment air lock with 10 CFR 50, m testing and valves with resilient seals, in Appendix J, accordance with 10 CFR 50, Appendix J, Option A, as b}
/
Option A, as modified by approved exemptions. modified by approved exemptions The leakage rate acceptance criterion is s 1.0 L,. However, during the first unit startup following testing performed in accordance with 10 CFR 50, Appendix J. Option A, as nodified by approved exempticas, t'.1e leakage rate acceptance criteria are < 0.6 L, for the Type B and Type C tests. l McGuire Unit 1 3.6-2 Supplement 2
, Centainment Air 'Lecks -
3.6.2
- 3.6 CONTAINMENT. SYSTEMS O 3.6.2 Containment Air Locks i
.LCO' 3.6.2 [Two containment air locks shall be' 0PERABLE.
' APPLICABILITY: MODES 1 2, 3, and'4.
ACTIONS
-------------------------------------NOTES-~-----------------------------------
- 1. Entry and exit is permissible to perform repairs on the affected air lock components.
- 2. Separate Condttion entry is allowed for each air lock.
- 3. Enter applicable Conditions and Required Actions of LCO 3.6.1,
" Containment," when air lock leakage results in exceeding the overall
-containment leakage rate.
CONDITION REQUIRED ACTI0h COMPLETION TIME L A. One or more ------------NOTES------------ containment air locks 1. Required Actions A.1, with one containment A.2, and A.3 are not air lock door applicable if both doors inoperable. in the same air lock are inoperable and Condition C is entered.
- 2. Entry and exit is permissible for 7 days under administrative controls if both air locks are inoperable.
(continued) j McGuire Unit 1 3.6-3 5/20/97 L
Containment Air Locks
-3.6.2 ACTIONS O CONDITION REQUIRED ACTION COMPLETION TIME A._(continued) A.1 Verify the OPERABLE . I hour door is closed in the affected air lock.
AliQ A.2 Lock the OPERABLE 24 hours door closed in the affected air lock. ARQ A.3 --------NOTE--------- Air lock doors in high radiation areas may be verified locked closed by administrative means. Verify the OPERABLE Once per 31 days F door is locked closed in the affected air lock. (continued) C) 3.6-4
~ 'McGuire Unit 1 5/20/97
Centainment Air Locks 3.6.2 ACTIONS (continued) O - _ _ CONDITION REQUIRED ACTION COMPLETION TIME B. One or more ------------NOTES------------ containment air locks 1. Required Actions B.1, with containment air- B.2, and B.3 are not lock interlock applicable if both doors mechanism inoparable. in the same air lock are inoperable and Condition C is entered.~
- 2. Entry and exit of.
containment is permissible under the control of a dedicated individual. B.1 Verify an OPERABLE - I hour door is closed in the affected air lock. M B.2 Lock an OPERABLE door 24 hours O closed in the affected air lock. M B.3 --------NOTE--------- Air lock doors in high radiation areas may be verified locked closed by administrative means. Verify an OPERABLE Once per 31 days door is locked closed in the affected air lock. (continued) 1
- \j-f"\ -l McGuire Unit 1 3.6-5 5/20/97
Containment' Air Lecks 3.6.2-ACTIONS (continued) CONDITION REQUIRED ACTION' COMPLETION TIME C. One or more C.1 Initiate action to Inmediately containment air locks- evaluate overall inoperable for reasons - containment leakage other than Condition A rate per LCO 3.6.1. or B. M C.2 Verify a door is 1 hour-closed in the affected air lock. M C.3 Restore air lock to 24 hours OPERABLE status. D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time not met. M D.2 Be in MODE 5. 36 hours i I i O v '
-McGuire Unit 1 3.6-6 5/20/97
-- ________ _b
Centainment Air Locks. 3.6.2 O SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 -------------------NOTES-------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock-leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in accordance with 10 CFR 50, Appendix J, -----NOTE------
Option A, as modified by approved SR 3.0.2 is not exemptions. applicable Perform required air lock leakage rate In accordance testing in accordance with 10 CFR 50, with 10 CFR 50, Appendix J, Option A, as modified by Appendix J, approved exemptions. Option A, as modified by The acceptance criteria for air lock approved testing are: exemptions
- a. Overall air lock leakage rate is s 0.05 L, when tested at 2 P,.
- b. For each door, leakage rate is < 0.01 L, when tested at 2 14.8 psig.
SR 3.6.2.2 Perform a pressure test on each inflatable 6 months air lock door seal and verify door seal leakage is < 15 sccm. SR 3.6.2.3 . Verify only one door in the air lock can be 18 months l opened at a time. O
<McGuire Unit 1 3.6-7 Supplement 2 l
Containment Isolaticn Valvos 3.6.?? 3.6 -CONTAINMENT SYSTEMS .M Q 3.6.3 ' Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE. APPLICABILITY: MODES 1, 2,.3, and 4. ACTIONS
-------------------------------------NOTES------------------------------------
- 1. . Penetration flow path (s) except for. containment purge supply and/or exhaust isolation valves for the lower compartment and instrument room may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.
- 4. Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when isolation valve leakage results in exceeding the l overall containment leakage rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Isolate the affected 4 hours Only applicable.to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves, de-activated
---------------------- automatic valve, closed manual valve, One or more blind flange, or penetration flow paths _ check valve inside with one containment containment with flow
, isolation valve through the valve inoperable except for secured, purge valve or reactor.
building bypass. Atta leakage not within limit. (continued) O 3.6-8 Supplement 2 l McGuire Unit 1-
Containment Isolatien Valvas 3.6.3 , ACTIONS (continued)' tO CONDITION REQUIRED ACTION. COMPLETION TIME < A. (continued) A.2 --------NOTE--------- Isolation devices in high radiation areas may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path for isolation is isolated. devices outside containment AE Prior to entering MODE. 4 from MODE 5 if not performed within the previous 92 days for isolation O devices inside containment B. ---------NOTE--------- 8.1 Isolate the affected 1 hour Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves. de-activated
---------------------- automatic valve, closed manual valve, One or more or blind flange.
penetration flow paths with two containment isolation valves inoperable except for purge valve or reactor building bypass leakage not within limit. (continued) McGuire Unit 1 3.6-9 5/20/97
Centainment Isolation Valvas 3.6.3 ACTIONS (continued) (q.) CONDITION REQUIRED ACTION COMPLETION TIME C. ---------NOTE--------- C.1 Isolate the affected 72 hours Only applicable to penetration flow path penetration flow paths by use of at least with only one one closed and , containment isolation de-activated valve and a closed automatic valve, system. closed manual valve,
---------------------- or blind flange.
One or nere M penetration flow paths with one containment C.2 --------NOTE--------- isolation valve Isolation devices in inoperable. high radiation areas may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path p V is isolated. D. Reactor building D.1 Restore leakage 4 hours bypass leakage not within limit. within limit. E. One or more E.1 Isolate the affected 24 hours I penetration flow penetration flow path paths with one or by use of at least more containment one closed and purge valves not de-activated within purge valve automatic valve, leakage limits. closed manual valve, or blind flange. M (continued)
)
G McGuire Unit 1 3.6-10 5/20/97
Containment Isolatien Valves 3.6.3' ACTIONS
' CONDITION : REQUIRED ACTION COMPLETION TIME E.'(continued) E.2 --------NOTE---------
Isolation devices in-high radiation areas may be verified by use of administrative means. Verify the affected Once per penetration flow path 31 days for is isolated. isolation devices outside containment M Prior to entering MODE 4 from MODE'5 if not performed within the O previous 92 days for isolation devices inside containment' M E.3 Perform SR 3.6.3.6 Once per l for the resilient 92 days seal purge valves closed to comply with Required Action E.1. F. Required Action and F.1 Be in MODE 3. 6 hours associated Completion Time not met. M F.2 Be in MODE 5. 36 hours
- McGuire Unit 1 3.6-11 Supplement 2 l
Containment Isolatien Valvas 3.6.3 p ' SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each containment' purge valve for the 31 days lower compartment and instrument room is sealed closed, except for one purge valve in a penetration flow path while in Condition E of this LCO. SR 3.6.3.2 Verify each containment purge and exhaust 31 days isolation valve for the upper compartment is closed, except when the valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. l SR 3.6.3.3 -------------------NOTE-------------------- Valves and blind flanges in high radiation areas may be verified by use of O administrative controls. Verify each containment isolation manual 31 days valve and blind flange that is located l outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions.is closed, except for containment isolationLvalves that are open under administrative controls'. (continued) O O
. l . McGuire . Unit 1 3.6-12. Supplement 2
Containment Isolaticn Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) \O SURVEILLANCE FREQUENCY SR '3.6.3.4 -------------------NOTE-------------------- l Valves and blind flanges in high radiation areas may be verified by use of administrative controls. Verify each containment isolation manual Prior to valve and blind flange that is located - entering MODE 4 inside containment or' annulus and not from MODE 5 if l locked, sealed, or otherwise secured and not perfonned required to be closed during accident within the. conditions is closed, except for previous containment isolation valves that are open 92 days under administrative controls. SR 3.6.3.5 Verify the isolation time of automatic. In accordance l power operated containment isolation valve with the is within limits. Inservice Testing Program SR 3.6.3.6 Perform leakage rate testing for 184 days l containment purge lower and upper compartment and Instrument room valves with A!H1 resilient seals. within 92 days after opening the valve SR 3.6.3.7 Verify each automatic containment isolation 18 months l valve that is not locked, sealed or
'otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.
(continued) O McGuire Unit 1 3.6-13 Supplement 2 l
Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS .( continued) O SURVEILLANCE FREQUENCY l SR 3.6.3.8 ------------------NOTE------------------- ------NOTE----- Penetrations not individually testable SR 3.0.2 is not shall be determined to have no visible applicable. leakage when tested with soap bubbles. ---------------
----------------------------------------- In accordance with 10 CFR 50, Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P , 14.8 approved psig. exemptions, for Type 8 and C testable-penetrations M
During SR 3.6.1.1 Type A tests for penetrations not O individually testable 1 .J' l; McGuire Unit 1 3.6-14 Supplement 2 j l
Ccntainment Pressure 3.6.4 g 3.6 CONTAINMENT SYSTEMS' 'V 3.6.4. Containment Pressure LCO 3.6.4 Containment pressure shall.be ;t -0.3 psig'and s +0.3 psig.
. APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment I hour not within limits. pressure to within limits. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within 12 hours limits. O McGuire Unit.'1 3.6-15 Supplement 2 l
Ccntainment Air Temp::rature 3.6.5
' 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO' 3.6.5 Containment average air temperature shall be:
- a. > 75'F and s 100*F for the containment upper compartment, and
- b. 2100*F and s 120*F for the containment lower compartment.
-----..--....---------------NOTES---------------------------
- 1. The minimum containment average air temperature in MODES E, 3, and 4 may'be reduced to 60*F.
- 2. Containment lower compartment temperature may be between 120 and 125'F for up to 90 cumulative days per calendar year provided lower compartment temperature average over the previous 365 days is less than 120*F. Within this 90 cumulative day period, lower compartment temperature may be between 125'F and 135'F for 72 cumulative hours.
J APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average A.1 Restore containment 8 hours air temperature not average air within limits, temperature to within limits. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours l McGuire Unit 1 3.6-16 Supplement 2
Containment Air Temperature 3.6.5 m ~ SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment upper compartment 24 hours average air temperature is within limits. SR 3.6.5.2 Verify containment lower compartment 24 hours average air temperature is within limits. O O McGuire Unit 1 3.6-17 Supplement 2 l ; i _______o
~-
Centainment Spray System
.3.6.6
'3.6- CONTAINMENT SYSTEMS
'3.6.6 Containment Spray: System-LCO 3.6.6 Two containment spray trains shall be OPERABLE.
' APPLICABILITY:- MODES 1, 2,.3, and 4.
-ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours train inoperable. spray train to OPERABLE status.
B.. Required Action'and 8.1 Be in MODE 3. 6 hours associated Completion i Time.not met. Afin 4 B.2 Be in MODE 5. 84 hours I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow
. path that is not locked, sealed, or otherwise secured in position is in the correct position.
(continued) !s i fl McGuire. Unit 1 3.6-18 Supplement 2 ,
Containment Spray System 3.6.6 n SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.6.2 Verify each containment spray pump's In accordance developed head at the flow test point is with the greater than or equal to the required Inservice developed head. Testing Program SR 3.6.6.3 Verify each automatic containment spray 18 months valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. SR 3.6.6.4 Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal. SR 3.6.6.5 Verify that each spray pump is de-energized 18 months and prevented from starting upon receipt of a terminate signal and is allowed to start upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.6.6 Verify that each spray pump discharge valve 18 months 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). SR 3.6.6.7 Verify each spray nozzle is unobstructed. 10 years I v McGuire Unit 1 3.6-19 Supplement 2 l
Hydroggn_Rtcombiners 3.6.7. 1 3.6 CONTAINMENT SYSTEMS 0 3.6.7: Hydrogen Recombiners LCol 3.6.7J Two hydrogen recombiners shall be OPERABLE.
-APPLICABILITY: . MODES 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION. TIME A. One hydrogen A.1 --------NOTE--------- recombiner inoperable. LCO 3.0.4 is not applicable. Restore hydrogen 30 days recombiner to OPERABLE status. O B. Required Action- and B.1 Be in MODE 3. 6 hours associated Completion Time not met. l McGuire Unit 1- 3.6 Supplement 2 : yi i-
Hydrogen Recombiners
.3.6.7 SURVEILLANCE REQUIREMENTS - SURVEILLANCE FREQUENCY SR 3.6.7.1 Perform a system functional test for each 18 months hydrogen recombiner.-
SR 3.6.7.2 Visually examine each hydrogen recombiner 18 months enclosure and verify there is no evidence of abnormal conditions. SR 3.6.7.3 Perform a resistance to ground test for- 18 months each heater phase. O O McGuire Unit 1 3.6-21 Supplement 2 l
o HSS 3.6.8 3.6 CONTAINMENT SYSTEMS' 3.6.8 HydrogenSkimmerSystem(HSS) 4 LCO 3.6.8 Two HSS trains shall be OPERABLE. APPLICABILITY:- MODES 1 and 2.
-ACTION'S CONDITION REQUIRED ACTION COMPLETION TIME A. One HSS train A.1 --------NOTE---------
inoperable. LC0 3.0.4 is~not applicable. Restore HSS train to 30 days OPERABLE status. O- B. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion Time not met.
'l'McGuireUnit1 3.6-22 Supplement 2
HSS
- 3.6.8 SURVEILLANCE REQUIREMENTS O SURVEILLANCE FREQUENCY SR 3.6.8.1 Operate each HSS train for 2 15 minutes. 92 days SR- 3.6.8.2. Verify the-fan motor current is s 21.5 amps.- 92 days when the fan speed is a 3579 rpm and s 3619 rpm with the hydrogen skinsner fan operating and the motor operated suction valve closed.
SR 3.6.8.3 Verify the motor operated suction valve 92 days opens automatically and the fans start upon receipt of a start permissive signal from the Containment Pressure Control System. 1 SR 3.6.8.4 Verify each HSS train starts on an actual 92 days or simulated actuation signal after a delay O of a 8 minutes and s 10 minutes. l h 'McGuire Unit 1 3.6-23 Supplement 2 l 4 r e , . .
HMS 3.6.9 3.6 CONTAINMENT SYSTEMS 3.6.9 Hydrogen Mitigation System (HMS) LCO 3.6.9 Two HMS trains shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One HMS train A.1 Restore HMS train to 7 days inoperable. OPERABLE status. DE A.2 Perform SR 3.6.9.1 on Once per 7 days the OPERABLE train. O B. One containment region with no OPERABLE B.1 Restore one hydrogen ignitor in the 7 days hydrogen ignitor. affected containment region to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met.
- f ,
f\.
~l"McGuire~ Unit-1 3.6 Supplement 2
HMS 3.6.9 SURVEILLANCE REQUIREMENTS O- SURVEILLANCE FREQUENCY SR 3.6.9.1 Energize each HMS train power supply 92 days breaker and verify a 34 ignitors are energized in each train. SR 3.6.9.2 Verify at least one hydrogen ignitor is 92 days OPERABLE in each containment region. SR 3.6.9.3 Energize each hydrogen ignitor and verify 18 months temperature is a 1700*F. O O 3.6-25 Supplement 2 McGuire Unit 1 l l m._ .
.(-
.AVS-3.6.10
'3.6:. CONTAINMENT SYSTEMS 3.6.10.. Annulus Ventilation System (AVS)
LLCO 3.6.10 Two AVS trains shall be OPERABLE.
' APPLICABILITY: MODES 1, 2, 3, and 4.-
ACTIONS CONDITION REQUIRED' ACTION COMPLETION TIME-A. One AVS-train A.1' Restore AVS train to 7 days inoperable. OPERABLE status. B. One or more AVS B.1 Restore AVS train (s) 7 days
. train (s) heater heater to OPERABLE inoperable. status.
O = B.2 Initiate action in 7 days accordance with Specification 5.6.6. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. Algl . C.2 Be in MODE 5. 36 hours O
; l f McGuire Unit 1 L. 3.6-26 Supplement 2 5
4
AVS' 3.6.10 SURVEILLANCE REQUIREMENTS
-L- SURVEILLANCE FREQUENCY.
SR 3.6.10.1 Operate each AVS' train for 210 continuous 31 days hours with heaters operating. SR 3.6.10.2 Perform required AVS filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program'(VFTP).
+___
SR 3.6.10.3 Verify each AVS train actuates on an actual 18 months or simulated actuation signal. SR 3.6.10.4 Verify each AVS filter cooling bypass valve 18 months can be opened. SR 3.6.10.5' Verify each AVS train flow rate is 2 7200 18 months cfm and s 8800 cfm. O McGuire Unit 1 - 3.6-27 . Supplement 2 l $=
I ARS 3.6.11 3.6 CONTAINMENT SYSTEMS V '3.6.11 Air Return System (ARS) LCO 3.6.11 Two ARS trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4.
. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ARS train A.1 Restore ARS train to 72 hours j inoperable. OPERABLE status, i B.. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND , B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.11.1 Verify each ARS fan starts on an actual or 92 days simulated actuation signal, after a delay of a 8 minutes and s 10 minutes, and operates for 2 15 minutes.
(continued) .m. ~
)
l McGuire Unit 1 3.6-28 Supplement 2
ARS 3.6.11 SURVEILLANCE REQUIREMENTS (continued) v SURVEILLANCE FREQUENCY SR 3.6.11.2 Verify, with the ARS fan damper closed and 92 days with the bypass dampers open, each ARS fan motor current is s 32.0 amps when the fan speed is 2 840 rpm and s 900 rpm. SR 3.6.11.3 Verify, with the ARS fan not operating, 92 days. each ARS motor operated damper opens automatically on an actual or simulated actuation signal after a delay of a 9 seconds and s 11 seconds. SR 3.6.11.4 Verify the check damper is open with the 92 days air return fan operating. SR 3.6.11.5 Verify the check damper is closed with the 92 days air return fan not operating. SR 3.6.11 6 Verify that each ARS fan is de-energized or 18 months is prevented from starting upon receipt of a terminate signal and is allowed to start upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.11.7 Verify that ARS fan motor-operated damper 18 months 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). D { l 3.6-29 Supplement 2 l McGuire. Unit 1 l
.. .- 1
Ice Bed 3.6.12 3.6 CONTAINMENT SYSTEMS "0 ~3.6.12. Ice Bed LCO 3.6.12 The ice bed shall be OPERABLE. APPLICABILITY:' MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME-A. Ice bed inoperable. A.1 Restore ice bed to 48 hours-OPERABLE status. B. Required Action and' B.1 Be in MODE 3. 6 hours-associated' Completion Time not met. AND B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR- 3.6.12.1 Verify maximum ice bed temperature is '12 hours s 27'F. (continued) i
- l- McGuire Unit 1 3.6-30 Supplement 2
)
Ice B:d 3.6.12 g SURVEIL' LANCE REQUIREMENTS (continued) V SURVEILLANCE FREQUENCY SR 3.6.12.2 . Verify total weight of stored ice is 9 months 2 2,099,790 lb by:
- a. Weighing a representative sample of a 144 ice baskets and verifying each basket.contains 21081 lb of ice; and
- b. Calculating total weight of stored ice, at a 95% confidence level,. using all ice basket weights determined in SR 3.6.12.2.a.
SR 3.6.12.3 Verify azimuthal distribution of ice at a 9 months 95% confidence level by subdividing weights, as determined by SR 3.6.12.2.a. into the following groups:
- a. Group 1-bays 1 through 8;
- b. Group 2-bays 9 through 16; and
- c. Group 3-bays 17 through 24.
The average ice weight of the sample baskets in each group from radial rows 1, 2, 4, 6, 8, and 9 shall be 2 1081 lb. SR 3.6.12.4 Verify, by visual inspection, accumulation 9 months of ice or frost on structural members comprising flow channels through the ice condenser is s 0.38 inch thick. (continued) 6 lV McGuire Unit 1 3.6-31 Supplement 2 l
Ice. Bad 3.6.12 SURVEILLANCE REQUIREMENTS (continued) O- SURVEILLANCE FREQUENCY SR 3.6.12.5- Verify by chemical analyses of'at least 18 months nine representative samples of' stored ice:
.a. Boron concentration is 2 1800 ppm; and
- b. pH.is'2 9.0 and s 9.5.
SR 3.6.12.6 Visually inspect, for detrimental 40 months structural wear, cracks, corrosion, or other damage, two ice baskets from each azimuthal group of bays. See SR 3.6.12.3. O O 3.6-32 Supplement 2
.l'McGuireUnit1
Ice Cendenstr Dosrs 3.6.13-
--3.6 CONTAINMENT SYSTEMS O 3.6.13 Ice Condenser Doors LCO' 3.6.13 The . ice condenser inlet doors, intermediate deck doors, and-top deck doors shall be OPERABLE and closed.- ' APPLICABILITY: MODES 1, 2, 3,'and 4.
ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each ice condenser-door. CONDITION REQUIRED ACTION COMPLETION. TIME A.- One or more ice A.1 Restore door to I hour condenser doors OPERABLE status. inoperable due to being physically O restrained from opening. B. -One or more ice B.1 Verify maximum ice Once per condenser doors bed temperature is 4 hours inoperable for reasons s 27'F. other than Condition A or not closed. AEl B.2 Restore ice condenser 14 days door to OPERABLE status and closed
. positions.
(continued) j O McGuire Unit'l 3.6-33 Supplement'2 'l
.___________b
Ice Cond2nser Dosrs 3.6.13 ACTIONS (continued)
\ CONDITION COMPLETION TIME REQUIRED ACTION C. Required Action and C.1 Restore ice condenser 48 hours associated Completion door to OPERABLE Time of Condition B- status and closed not' met. positions.
D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AlH1 or C not met. D.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY A V Verify all inlet doors indicate closed by 12 hours SR 3.6.13.1 the Inlet Door Position Monitoring System. SR 3.6.13.2 Verify, by visual' inspection, each 7 days intermediate deck door is closed and not impaired by ice, frost, or debris. SR 3.6.13.3 Verify, by visual inspection, each-top de'ck 92 days door:
- a. Is in place; and
- b. Has no condensation, frost, or ice formed on the door that would' restrict its opening.
(cont'inued) l.LMcGuire Unit 1 3.6-34 Supplement 2
Ice Cendenser Doors 3.6.13 SURVEILLANCE' REQUIREMENTS (continued) O~ SURVEILLANCE FREQUENCY SR 3.6.13.4 Verify, by visual inspection, each inlet 18 months door is not impaired by ice, frost, or debris. SR. 3.6.13.5 Verify torque required to cause each inlet 18 months door to begin to open is s 675 in-lb. SR 3.6.'13.6 Perform a torque test on each inlet door. 18 months SR 3.6.13.7 Verify for each intermediate deck door: 18 months
- a. No visual evidence of structural deterioration;
- b. Free movement of the vent assemblies; O and
- c. Free movement of the door.
':5
-.McGuire Unit l'. 3.6-35 Supplement 2- l
Dividar Barrier Inttgrity. 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Divider Barrier Integrity LCO 3.6.14 Divider barrier integrity shall be maintained.- APPLICABILITY:- MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. .---------NOTE--------- A.1 Restore personnel I hour For this action, access doors and separate Condition equipment hatches to entry is allowed for 0PERABLE status and each personnel access closed positions. door or equipment hatch. One or more personnel O- access doors or equipment hatches open or inoperable, other than for personnel transit entry. B. Divider barrier seal B.1 Restore seal to I hour inoperable. OPERABLE status.
.C. Required Action and C.1 Be in MODE 3. 6 hours associated ~ Completion Time not met. AtiQ C.2 Be in MODE 5. 36 hours l LMcGuire Unit 1 3.6-36 Supplement 2 t
_ . _ . . . . . . _ . _ . _ . . . . . _ _ . . . . . . . . . . 1
Divider Barrier Integrity 3.6.14 SURVEILLANCE REQUIREMENTS O SURVEILLANCE FREQUENCY- ;
'SR 3.6.14.1 Verify, by visual inspection, all personnel _ Prior to access doors and equipment hatches between entering MODE 4 1 upper and lower containment compartments from MODE 5 are closed.
SR 3.6.14.2 Verify, by visual inspection, that the Prior to final seals and sealing surfaces of each closure after personnel access door and equipment hatch each opening. have: Afia
- a. No detrimental misalignments;
-----NOTE------
- b. No cracks or defects in the sealing Only required surfaces; and for seals made of resilient.
- c. No apparent deterioration of the seal materials material . ---------------
10 years SR 3.6.14.3 Verify, by visual inspection, each After each personnel access door or equipment hatch opening that has been opened for personnel transit entry is closed. SR 3.6.14.4 Remove two divider barrier seal test 18 months coupons and verify both test coupons' tensile strength is a 39.7 psi. (continued) O V McGuire Unit _1 3.6-37 Supplement 2 l _______o
Divider Barrier Integrity 3.6.14 SURVEILLANCE REQUIREMENTS (continued) O. SURVEILLANCE FREQUENCY SR 3.6.14.5 Visually inspect > 95% of the divider 18 months barrier seal length, and verify:
- a. Seal and seal mounting bolts are properly installed; and
- b. Seal material shows no evidence of deterioration due to holes, ruptures, chemical attack, abrasion, radiation damage, or changes in physical appearance.
O O . l McGuire Unit 1 3.6-38 Supplement 2
Containment' Recirculation Drains 3.6.15 3.6 CONTAINMENT' SYSTEMS 3.6.15 Containment; Recirculation Drains LCO 3.6.15 The ice condenser floor drains and the refueling canal drains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
.A. One ice condenser A.1 Restore ice condenser 1 hour floor drain floor drain to inoperable. OPERABLE status.
B. .One refueling canal B.1 Restore refueling 1 hour drain inoperable. canal drain to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours . m McGuire Unit 1. 3.6-39 Supplement 2 l
r
' Containment Rscirculatien Drains 3.6.15.
c SURVEILLANCE REQUIREMENTS
. SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.6.15.1 Verify, by visual inspection, that: Prior to entering MODE 4
- a. Each refueling canal-drain valve is from MODE.5-locked open; after each-partial or
- b. Each refueling canal drain is not. complete fill obstructed by debris; and of the canal SR 3.6.15.2 Verify, by visual inspection, that no 92 days debris is present in the-upper compartment or refueling canal that could obstruct the refueling canal drain.
SR 3.6.15.3 Verify for each ice condenser floor drain 18 months that the:
- a. Valve opening is not impaired by ice, O b.
frost, or debris; Valve seat shows no evidence of damage;
- c. Valve opening force is s 66 lb; and
- d. Drain line from the ice condenser floor to the lower compartment is unrestricted.
O ;l: McGuire Unit 1. 3.6-40 Supplement 2
R5actorBuilding
.3.6.16 3.6 CONTAINMENT SYSTEMS 3.6.16 Reactor Building
'LCO 3.6.16 The reactor building shall be 0PERABLE.
APPLICABILITY:- MODES 1, 2, 3, and 4. ACTIONS' CONDITION REQUIRED ACTION. COMPLETION. TIME A. Reactor building A.1 Restore reactor 24 hours
. inoperable, building to OPERABLE status.
B. Required Action and B.1 -Be in MODE 3. 6 hours associated Completion Time not met. Algl B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.16.1 Verify each door in each access opening is 31 days closed, except when the access opening is
.being used for normal transit entry and exit; then,'at least one door shall be closed.
(continued)
!McGuireUnit1 3.6-41 Supplement 2 l
R actor Building 3.6.16 1 SURVEILLANCE FREQUENCY SR 3.6.16.2 Verify each Annulus Ventilation System 18 months on a train produces a pressure eaual to or more STAGGERED TEST negative than -0.5 inch water gauge in the BASIS annulus within 22 seconds after a start' signal and -3.5 inches ~ water gauge after 48 seconds. Verifyin'g that upon reaching a negative pressure of -3.5 inches water gauge in the annulus, the system switches into its recirculation mode of operation and that the time required for the annulus pressure to increase to -0.5 inch water. gauge is a 278 seconds. SR 3.6.16.3 Verify reactor building structural 40 months integrity by performing a visual inspection of the exposed interior and exterior afiQ surfaces of.the reactor building. During shutdown for SR 3.6.1.1 Type A tests O 3.6-42 Supplement 2 l : McGuire Unit 1
Centainment 3.6.1 3.6 '. CONTAINMENT SYSTEMS 3.6.1 Containment LCO' 3.6.1 Containment shall be OPERABLE. APPLICASILITY: MODES 1, 2, 3, and 4.
' ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment A.1 Restore containment I hour inoperable. to OPERABLE status.-
B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AE B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 --------------------NOTE------------------ The space between each dual ply bellows assembly on-penetrations between the containment building and annulus shall be
. vented to the annulus during Type A tests.
Perform required visual examinations and In accordance Type ALleakage rate testing in accordance with the l with the Containment Leakage Rate Testing Containment
. Program. Leakage Rate Testing Program (continued) i(X Q
McGuire Unit 2 3.6-1 Supplement 2 l s
Centainment 3.6.1 SURVEILLANCE REQUIREMENTS (continued) V SURVEILLANCE FREQUENCY SR 3.6.1.2 --------------------NOTE------------------
- 1. Following each Type A test, the space between each' dual-ply bellows assembly shall be subjected to a low pressure test at 3 to 5 psig to verify no detectable leakage, or the assembly shall be subjected to a leak test with the pressure on the containment side of the assembly at Pa.
- 2. Type C tests on penetrations M372 and M373 may be performed without draining the glycol-water mixture from the seats of their diaphragm valves if -----NOTE------
meeting a zero indicated leakage rate SR 3.0.2 is not (not including instrument error). applicable Perform required Type B and C leakage rate In accordance testing, except for containment air lock with 10 CFR 50, testing and valves with resilient seals, in Appendix J. 9 accordance with 10 CFR 50, Appendix J. Option A, as (V Option A, as modified by approved exemptions. modified by approved exemptions The leakage rate acceptance criterion is s 1.0 L,. However, during the first unit startup following testing performed in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions, the leakage rate acceptance criteria are < 0.6 L, for the Type B and Type C tests. l i _r V] l l McGuire Unit 2 3.6-2 Supplement 2
1 Centainment Air Lecks 3.6.2 l i 3.6 CONTAINMENT SYSTEMS O,' 3.6.2 Containment Air Locks LC0 3.6.2 Two containmant air locks shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS-
------- ---_------------_------- ---_ NOTES------------------------------------
- 1. Entry and exit is permissible to perform repairs on the affected air lock
. components.
- 2. Separate Condition entry is allowed for each air lock.
- 3. -Enter applicable Conditions and Required Actions of LC0 3.6.1,
" Containment," when air lock leakage results in exceeding the overall containment leakage rate.
p CONDITION REQUIRED ACTION COMPLETION TIME V i A. One or more ------------NOTES------------ containment air locks 1. Required Actions A.1, with one containment A.2, and A.3 are not air lock door applicable if both doors inoperable. in the same air lock are inoperable and Condition C is entered.
- 2. Entry and exit is permissible for 7 days under administrative controls if both air locks are inoperable.
(continued) i t
'U )
McGuire Unit 2 3.6-3 5/20/97 i
Containment Air Lccks 3.6.2 CONDITION REQUIRED ACTION COMPLETION. TIME A. (continued) A.1 Verify the OPERABLE 1 hour door is closed in the affected air lock. i AM A.2 Lock the OPERABLE 24 hours door closed in the affected air lock. AE A.3 --------NOTE--------- Air lock doors in high radiation areas may be verified locked closed by administrative means. Verify the OPERABLE Once per 31 days door is locked closed O in the affected air lock. (continued) O -McGuire Unit 2 3.6-4 5/20/97
Centainment Air Lecks 3.6.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. 'One or more ------------NOTES------------ containment air locks 1. Required Actions B.1, with containment air B.2, and B.3 are not lock interlock applicable if both doors mechanism inoperable. in the same air lock are inoperable and Condition C is entered.
- 2. Entry and exit of containment is permissible under the control of a dedicated individual.
B.1 Verify an OPERABLE 1 hour door is closed in the affected air lock. M B.2 Lock an OPERABLE door 24 hours O-closed in the affected air lock. M B.3 --------NOTE--------- Air lock doors in high radiation areas may be verified locked closed by administrative means. Verify an OPERABLE Once per 31 days door is locked closed in the affected air lock. (continued) ]./ McGuire Unit 2 3.6-5 5/20/97
Centainment Air Lecks 3.6.2 q ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One or more C.1 Initiate action to Immediately containment air locks evaluate overall inoperable for reasons containment leakage other than Condition A rate per LC0 3.6.1. or B. M C.2 Verify a door is I hour closed in the affected air lock. M C.3 Restore air lock to 24 hours OPERABLE status. D. Required Action and 0.1 Be in MODE 3. 6 hours associated Completion Time not met. M D.2 Be in MODE 5. 36 hours I i ij j) Lj McGuire _ Unit-2 3.6-6 -5/20/97 i i
Containment Air Locks 3.6.2 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 -------------------NOTES-------------------
- 1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock -1 leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.2 in accordance with 10 CFR 50, Appendix J, -----NOTE------
Option A, as modified by approved SR 3.0.2 is not exemptions. applicable Perform required air lock leakage rate In accordance testing in accordance with 10 CFR 50, with 10 CFR 50, Appendix J, Option A, as modified by Appendix J, approved exemptions. Option A, as modified by The acceptance criteria for air lock approved testing are: exemptions , a. Overall air lock leakage rate is ( s 0.05 L, when tested at a P,. - l
- b. For each door, leakage rate is < 0.01 L, when tested at 2 14.8 psig.
l SR 3.6.2.2 Perform a pressure test on each inflatable 6 months air lock door seal and verify door seal leakage is < 15 sccm. SR 3.6.2.3 Verify only one door. in the air lock can be 18 months l
~ opened at a time.
McGuire Unit-2 3.6-7 Supplement 2 l i i
Containment Isolaticn Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
-------------------------------------NOTES------------------------------------ 1
- 1. Penetration flow path (s) except for containment purge supply and/or exhaust isolation valves for the lower compartment and instrument room may be unisolated intermittently under administrative controls.
- 2. LSeparate. Condition entry is allowed for each penetration flow path. 1
- 3. Enter applicable Conditions and Required Actions for systems made <
inoperable by containment isolation valves. (
- 4. Enter applicable Conditions and Required Actions of LCO 3.6.1,
~" Containment," when isolation valve leakage results in exceeding the l . overall . containment leakage _ rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Isolate the affected 4 hours Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves, de-activated
---------------------- automatic valve, closed manual valve,
-One or more blind flange, or penetration flow paths check valve inside with one containment containment with flow isolation valve through the' valve inoperable except for secured.
purge valve or reactor building bypass MiQ 1eakage not within limit. (continued)
- l. 'l McGuire- Unit 2 3.6-8 Supplement 2
L Centainment Isolaticn Valvas
- l. -3.6.3 i ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME I A. (continued) A.2 --------NOTE--------- Isolation devices in high radiation areas may be verified by use of administrative means. ___.......____....... i Verify the affected Once per 31 days I penetration flow path for isolation is isolated. devices outside l containment i AliQ Prior to i entering MODE 4 l from MODE 5 if not performed ! within the previous 92 days for isolation O- devices inside containment B. ---------NOVE--------- B.1 Isolate the affected I hour Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isolation valves. de-activated
---------------------- automatic valve, closed manual valve, One or more or blind flange.
penetration flow paths with two containment isolation valves inoperable except for purge valve or reactor building bypass leakage not within limit. (continued) O V
-McGuire Unit 2 3.6-9 5/20/97
C:ntainment Isolation Valycs
-3.6.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME: C. ---------NOTE--------- C.1 Isolate the affected 72 hours
. Only^ applicable to penetration flow path penetration flow paths by.use of at least with only one .
one closed and containment isolation de-activated vahe and a closed automatic valve, system. closed manual valve,.
................------ or blind flange.
One or more Atl0 penetration flow paths with one containment C.2 --------NOTE--------- isolation valve Isolation devices in inoperable. high radiation areas may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path p is isolated. V s D.. Reactor butiding. D.1 Restore leakage 4 hours }" bypass leakage not within limit. within limit. E. One or more E.1 Isolate the affected 24 hours penetration flow penetration flow path paths with one or by use of at least more containment one closed and purge valves not de-activated within purge valve automatic valve, leakage limits. closed manual valve, or blind flange. AliQ (continued)
-k McGuire Unit.2' 3.6-10 5/20/97 i
l
Containment Is01atien Valvas 3.6.3 O ACTIONS b CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) E.2 --------NOTE--------- Isolation devices in high radiation areas may be verified by use of administrative neans. Verify the affected Once per penetration flow path 31 days for is isolated. isolation devices outside containment M Prior to entering MODE 4 from MODE 5 if not performed within the previous O' 92 days for isolation devices inside containment M E.3 Perform SR 3.6.3.6 Once per l for the resilient 92 days seal purge valves closed to comply with ; Required Action E.1. F. Required Action and F.1 Be in MODE 3. 6 hours associated Completion Time not met. M , F.2 Be in MODE 5. 36 hours
-( )
McGuire Unit 2 3.6-11 Supplement 2 l
Centainment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS / (O,/ SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each containment purge valve for the 31 days lower compartment and instrument room is sealed closed, except for one purge valve in a penetration flow path while in Condition E of this LCO. SR 3.6.3.2 Verify each containment purge and exhaust 31 days isolation valve for the upper compartment is closed, except when the valves are open for pressure control, ALARA or air qualit; considerations for personnel entry, or for Surveillances that require the valves to be open. l SR 3.6.3.3 -------------------NOTE-------------------- Valves and blind flanges in high radiation areas may be verified by use of I- $ IS" I-------------------- Verify each containment isolation manual 31 days valve and blind flange that is located l l outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls. 1 (continued) l O s l McGuire Unit 2 3.6-12 Supplenent 2 ) l l l l l
Centainment Isolaticn Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) O SURVEILLANCE FREQUENCY
.SR 3.6.3.4 -------------------NOTE.------------------- l.
Valves and blind flanges in high radiation areas may be verified by use c-f administrative controls. Verify each containment isolation manual Prior to valve and blind flange that is. located entering MODE 4 inside containment or annulus and not from MODE 5 if l locked, sealed, or otherwise secured and not performed required to be closed during accident within the conditions is closed, except for previous containment isolation valves that are open 92 days under administrative controls. SR 3.6.3.5 Verify the isolation time of automatic In accordance l power operated containment isolation valve with the is within limits. Inservice Testing Program i O V SR 3.6.3.6 Perform leakage rate testing for 184 days l containment purge lower and upper compartment and Instrument room valves with AlH1 resilient seals. within 92 days after opening the valve SR 3.6.3.7 Verify each automatic containment isolation 18 months l valve that is not locked, sealed or
'otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.
(continued)
-McGuire. Unit 2 3.6-13 Supplement 2 l l
. . .1
-Centainment Isolatien Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY l SR 3.6.3.8 ------------------NOTE------------------- ------NOTE----- Penetrations not individually testable SR 3.0.2 is not shall be determined to have no visible applicable. leakage when tested with soap bubbles. ---------------
----------------------------------------- In accordance with 10 CFR 50, Verify the combined leakage rate for all Appendix J, as reactor building bypass leakage paths is modified by s 0.07 L, when pressurized to P., 14.8 approved psig, exemptions, for Type B and C testable penetrations AM During SR 3.6.1.1 Type A tests for penetrations not i individually testable l McGuire Unit 2 3.6-14 Supplement 2
Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be 2 -0.3 psig and s +0.3 psig. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment I hour not within limits. pressure to within limits. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. M(1 B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within 12 hours limits. FN V. McGuire Unit 2 3.6-15 Supplement 2 l
C ntainment Air Temp 2rature 3.6.5 3.6 CONTAINMENT SYSTEMS 10 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be:
- a. > 75'F and s 100*F for the containment upper compartment, and
- b. 2 100*F and s 120*F for the containment lower compartment.
----------------------------NOTES---------------------------
- 1. The minimum containment average air temperature in MODES 2, 3, and 4 may be reduced to 60*F.
- 2. Containment lower compartment temperature may be between 120 and 125*F for up to 90 cumulative days per calendar year provided lower compartment temperature average over the previous 365 days is less than 120*F. Within this 90 cumulative day period, lower compartment temperature may be between 125*F and 135*F for 72 cumulative hours.
APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average A.1 Restore containment 8 hours air temperature not average air within limits, temperature to within limits. i B. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion Time not met. AM B.2 Be in MODE 5. 36 hours n. U l McGuire Unit 2 3.6-16 ' Supplement 2
- Containment Air Temperatura-3.6.5 SURVEILLANCE REQUIREMENTS
' SURVEILLANCE FREQUENCY 1 SR 3. 6. 5.1 ' Verify containment upper compartment 24 hours I
average air temperature is within limits. SR 3.6.5.2 Verify containment lower compartment 24 hours average air temg ature is within limits. O
;O McGuire Unit 2 3.6-17' Supplement 2 l
Ccntainment Spray System 3.6.6 3.6.. CONTAINMENT. SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3 and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours train inoperable. spray train to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. A!H1 B.2 Be in MODE 5. 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow
. path that is not locked, sealed, or otherwise secured in position is in the correct position. J (continued) l lMcGuire Unit 2 .3.6-18 Supplement 2'
Centainment Spray System 3.6.6 SURVEILLANCE' REQUIREMENTS (continued) SURVEILLANCE FREQUENCY-
'SR'. 3.6.6.2 Verify each containment spray pump's 'In accordance developed head at the flow test point is with the greater than or. equal to the required Inservice developed head. Tes^ing Program SR' 3.6.6.3 Verify each automatic containment.. spray 18 months valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.6.6.4- Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal. SR 3.6.6.5 Verify that each spray pump is de-energized 18 months and prevented from starting upon receipt of a terminate signal and is allowed to start upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.6.6 Verify that each spray pump discharge valve 18 months 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). SR 3.6.6.7 Verify each spray nozzle is unobstructed. 10 years St McGuire Unit 2 3.6-19 Supplement 2 l
Hydrog:n R combiners 3.6.7 3.6- CONTAINMENT SYSTEMS 3.6.7 Hydrogen Recombiners-LCO '3.6.7 Two hydrogen recombiners shall be OPERABLE.
~ APPLICABILITY: MODES 1 and 2..
ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME-A. One hydrogen A.1 --------NOTE--------- recombiner inoperable. LCO 3.0.4 is not applicable. Restore hydrogen 30 days recombiner to OPERABLE status. O B. Required Action and B.I Be in MODE 3. 6 hours associated Completion Time not met. i
)
O 3.6-20 Supplement.2
. l L McGuire Unit 2
'- Hydrogsn Recombinars J 3.6.7. 1 I SURVEILLANCE REQUIREMENTS O SURVEILLANCE FREQUENCY-
)
SR 3.6.7.1 Perform a' system functional test for each 18 months hydrogen recombiner. SR 3.6.7.2 Visually examine each hydrogen recombiner 18 months enclosure and verify there is no evidence of abnormal conditions.
.SR 3.6.7.3 Perform a resistance to ground test for 18 months each heater phase.
O O McGuire Unit 2 3.6-21 . Supplement 2 l
w, HSS 3.6.8-3.6 CONTAINMENT SYSTEMS 3.6.8 HydrogenSkimmerSystem(HSS) LCO 3.6.8 Two HSS trains shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION- COMPLETION TIME A. One HSS train A.1 --------NOTE--------- inoperable. LC0 3.0.4 is not applicable. Restore HSS train to 30 days OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. I l [ McGuire Unit 2 3.6-22 Supplement 2 i
HSS 3.6.8 SURVEILLANCE. REQUIREMENTS-SURVEILLANCE FREQUENCY SR 3.6.8.1 Operate each HSS train for 2 15 minutes. 92 days SR 3.6.8.2 Verify the fan motor current is s 21.5 amps 92 days when the fan speed is 2 3579 rpm and s 3619 rpm with the hydrogen skimmer fan operating and the motor operated suction valve closed.
-SR- 3 6.8.3 Verify the notor operated suction valve 92 days opens automatically and the fans start upon receipt of a start permissive signal from the Containment Pressure Control System.
SR 3.6.8.4 Verify each HSS train starts on an actual 92 days or simulated actuation signal after a delay O of 2 8 minutes and s 10 minutes. O McGuire Unit 2 3.6-23 _ Supplement 2 l
HMS 3.6.9 3.6 CONTAINMENT SYSTEMS 3.6.9 Hydrogen Mitigation System (HMS) LCO 3.6.9 Two HMS trains shall be OPERABLE. APPLICABILI'TY: MODES 1 and 2. ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME A. One HMS train A.1 Restore HMS train to 7 days inoperable. OPERABLE status. DE A.2 Perform SR 3.6.9.1 on Once per 7 days the OPERABLE train. B. One containment region B.1 Restore one hydrogen 7 days with no OPERABLE ignitor in the hydrogen ignitor. affected containment , region to OPERABLE status. ) C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. O ' L .) . l l -McGuire Unit 2 3.6-24 Supplement 2
HMS 3.6.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.9.1 Energize each HMS train power supply 92. days , breaker and verify 2 34 ignitors are energized in each train. 3 SR 3.6.9.2 Verify at least one hydrogen ignitor is 92. days - OPERABLE in each containment region. , I l ( SR 3.6.9.3 Energize each hydrogen ignitor and verify 18 months temperature is a 1700'F. 1 I O O McGuire Unit 2 3.6-25 Supplement 2 l ! i 1
AVS 3.6.10'- g 3.6 CONTAINMENT SYSTEMS U 3.6.10 Annulus Ventilation System ~(AVS) LCO. 3.6.10 .Two AVS trains shall be OPERABLE. i APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One AVS train A.1 Restore AVS train to 7 days inoperable. OPERABLE status. B. One or more AVS B.1 Restore AVS train (s) 7 days train (s) heater heater to OPERABLE inoperable. status.
=
O B.2 Initiate action in 7 days accordance with Specification 5.6.6. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AM C.2 Be in MODE 5. 36 hours O U l McGuire Unit 2 3.6-26 Supplement 2
AVS 3.6.10 gs SURVEILLANCE REQUIREMENTS D SURVEILLANCE FREQUENCY SR 3.6.10.1 Operate each AVS train for 2 10 continuous 31 days hours with heaters operating. SR 3.6.10.2 Perform required AVS filter testing in In accordance accordance with the Ventilation Filter' with the VFTP Testing Program (VFTP). SR 3.6.10.3 Verify each AVS train actuates on an actual 18 months or simulated actuation signal. SR 3.6.10.4 Verify each AVS filter cooling bypass valve 18 months can be opened. SR 3.6.10.5 Verify each AVS train flow rate is 2 7200 18 months cfm and s 8800 cfm.
\
l ..n), (. McGuire Unit 2 3.6-27 Supplement 2 l
ARS. 3.6.11 3.6 CONTAINMENT SYSTEMS 3.6.11. Air Return System (ARS) LCO 3.6.11 Two ARS trains shall be OPERABLE.
' APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ARS train A.1 Restore ARS train to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. &E B.2 Be in MODE 5. 36 hours
-SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.11.1 Verify each ARS fan starts on an actual or 92 days simulated actuation signal, after a delay of 2 8 minutes and s 10 minutes, and operates for 215 minutes.
(continued) O . l .f McGuire Unit 2 3.6-28 Supplement 2
ARS 3.6.11. SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE. FREQl'ENCY
~
SR 3.6.11'.2 Verify, with the ARS fan damper closed and 92' days with the. bypass dampers open, each ARS fan motor current is -s 32.0 amps when the fan speed is 2 840 rpm and s 900 rpm. SR 3.6.11.3 Verify, with the ARS fan not operating, 92 days each ARS motor operated damper opens automatically on an actual or simulated actuation signal after a delay of a 9 seconds and s 11 seconds.
.SR. 3.6.11.4 Verify the check damper is open with the 92 days air return fan operating.
SR 3.6.11.5 Verify the check damper is closed with the 92 days air return fan not operating. SR 3.6.11.6 Verify that each ARS fan is de-energized or 18 months is prevented from starting upon receipt of a terminate signal and is allowed to start upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.11.7 Verify that ARS fan motor-operated damper 18 months 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). O McGuire Unit 2 3.6-29 Supplement 2 - l
Ice bed-3.6.12 3.6 CONTAINMENT SYSTEMS 3.6.12 Ice Bed LCO 3.6.12 The ice bed shall'be OPERABLE.
' APPLICABILITY:- MODES 1, 2, 3, and 4.
- ACTIONS' CONDITION REQUIRED ACTION COMPLETION TIME' A. Ice bed inoperable. A.1 Restore ice bed.to 48 hours OPERABLE status.
B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. A!H1 B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR' 3.6.12.1 Verify maximum ice bed temperature is 12 hours s 27'F. ; (continued)
'J l McGuire Unit 2 3.6-30 Supplement 2 l
t Ice 8:d 3.6.12 SURVEILLANCE REQUIREMENTS (continued)- SURVEILLANCE FREQUENCY SRJ3.6.12.2 Verify total weight of stored ice is 9 months a 2,099,790 lb by:
- a. Weighing a representative sample of a 144. ice baskets and verifying each basket.contains a 1081 lb of ice; and
- b. Calculating total' weight of stored ice, at a 95% confidence level, using all ice basket weights determined in SR 3.6.12.2.a.
SR 3.6.12;3 Verify azimuthal distribution of ice at a 9 months. 95% confidence level by subdividing weights, as determined by SR 3.6.12.2.a. into the following groups:
- a. Group 1-bays 1 through 8;
- b. Group 2-bays 9 through 16; and
- c. Group 3-bays 17 through 24.
The average ice weight of the sample baskets in each group from radial rows 1, 2, 4, 6, 8, and 9 shall- be 2 1081 lb. SR 3.6.12.4 Verify, by visual inspection, accumulation 9 months of ice or frost on structural members comprising flow channels through the ice condenser is s 0.38 inch thick. (continued) p}..
\
McGuire Unit 2 3.6-31 Supplet.i;# 2 l 4
Ice B:d 3.6.12 4 g SURVEILLANCE REQUIREMENTS (continued) ( SURVEILLANCE FREQUENCY SR 3.6.12.5 Verify by chemical analyses of at least 18 months nine representative samples of stored ice:
- a. Boron concentration is a 1800 ppm; and
- b. pH is a 9.0 and s 9.5.
SR 3.6.12.6 Visually inspect, for detrimental 40 months structural wear, cracks, corrosion, or other damage, two ice baskets from each azimuthal group of bays. See SR 3.6.12.3. O O -l McGuire Unit 2 3.6-32 Supplement 2
Ice Cendenser D: ors. 3.6.13
'3.6_ CONTAINMENT. SYSTEMS O 3.6.13 Ice Condenser. Doors' ,
LC0. 3.6.13 The ice condenser inlet doors, intermediate deck doors, and top deck doors shall be' 0PERABLE and closed. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
-------------------------------------NOTE---'----------------------------------
Separate Condition entry is allowed for each ice. condenser door. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more ice A.1 Restore door to I hour condenser doors OPERABLE status. I inoperable.due to being physically O restrained from opening. B. One or more ice B.1 Verify maximum ice Once per condenser doors bed temperature is 4 hours inoperable for reasons s 27'F. Other than Condition A or not closed. AM1 B.2 Restore ice condenser 14 days door to OPERABLE status and closed positions. (continued) I McGuire Unit 2 3.6-33 Supplenent 2 l
Lice Cendrnsar Dosrs 3.6.13 ACTIONS-(continued) CONDITION REQUIRED ACTION COMPLETION TIME
'C. Required Action and C.1 REstoreicecondenser 48 hours associated Completion -door to OPERABLE Time of Condition 8 status and closed not met. positions.
D. Required Action and D.1 Be in M0DE 3. 6 hours associated Completion
- Time of Condition A AEt or C not met.
D.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY O SR 3.6.13.1 Verify all inlet doors indicate closed by 12 hours the Inlet Door Position Monitoring System. SR 3.6.13.2 Verify, by visual inspection, each 7 days intermediate deck door is closed and not impaired by ice, frost, or. debris. SR 3.6.13.3 Verify, by visual inspection, each top deck 92 days door:
- a. Is in place; and
- b. Has no condensation, frost, or ice formed on the door that would restrict
'its opening.
(continued).
-ll McGuire Unit 2 3.6-34 Supplement 2
l Ice Condtnstr Doors 3.6.13 SURVEILLANCE REQUIREMENTS. (continued) O SURVEILLANCE FREQUENCY SR 3.6.13.4 Verify, by visual inspection, each inlet 18. months door is not impaired by ice, frost, or debris. SR 3.6.13.5 Verify torque required to cause each inlet 18 months door to begin to open is s 675 in-lb.
.SR 3.6.13.6 Perform a torque test on each inlet door. 18 months
.SR 3.6.13.7 Verify for each intermediate deck door: 18 months
- a. No visual evidence of structural deterioration;
- b. Free movement of the vent assemblies; and
- c. Free movement of the door. ,
cp%s
.McGuire, Unit 2 3.6-35 Supplement 2 l
Divider Barrier Integrity - 3.6.14-3.6 CONTAINMENT SYSTEMS O 3.6.14 Divider Barrier Integrity LCO 3.6.14 Divider barrier integrity shall_ be maintained. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- _ A .1 Restore personnel I hour For this action, access doors and separate Condition equipment hatches to entry is' allowed for OPERABLE status and each personnel access closed positions. door or equipment hatch.
, One or more personnel access doors or equipment hatches open or inoperable, other than for personnel transit entry.
B. Divider barrier seal B.1 Restore seal to I hour inoperable. OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated ~ Completion Time not met. ARQ C.2 Be in MODE 5. 36 hours l McGuire Unit- 2' _3.6-36 Supplement 2
I-P Divider Barrier Intcgrity !' 3.6.14 i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1' Verify, by visual inspection, all. personnel Prior to access doors and equipment hatches between entering MODE 4 upper and lower containment compartments from MODE 5 are closed. SR~ 3.6.13.2 Verify, by visual inspection, that the Prior to final seals and sealing surfaces of each closure after personnel access door and equipment hatch each opening have: Alm i
- a. No detrimental misalignments;
-----NOTE------
- b. No. cracks or defects in the sealing Only required I l surfaces; and for seals made of resilient
- c. No apparent deterioration of the seal materials materi al . - ---------------
10 years j O _ ! SR 3.6.14.3 Verify, by visual inspection, each After each personnel access door or equipment hatch opening ' that has been opened for personnel transit entry is closed. l SR 3.6.14.4 Remove two divider barrier seal test 18 months ! coupons and verify both test coupons' tensile strength is 2 39.7 psi. (continued) O McGuire Unit 2- 3.6-37 Supplement 2 l
. _ _ - _ _ _ = _ _ .
Divider 8arrier Integrity 3.6.14 m SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR : 3.6.14.5 Visually inspect a 95% of.the divider 18 months barrier seal length, and verify:.
- a. Seal and seal mounting bolts are properly installed; and
- b. ' Seal material shows no evidence of deterioration due to holes, ruptures,
' chemical attack, abrasion, radiation damage, or changes in physical appearance.
O m Y) l ; McGuire Unit' 2 - 3.6-38 Supplement' 2 m
"4 , Centainment R:circulaticn Drains 3.6.15
-3.'6l CONTAINMENT SYSTEMS 3.6.15: Containment Recirculation Drains -LCO. 3.6.15 The ice condenser floor drains and the refueling canal drains sha.11 be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
~ CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser A.1 Restore ice condenser 1 hour floor drain ' floor drain to.
inoperable.. OPERABLE status. B. -One refueling canal H.1 Restore refueling i hour drain inoperable. canal drain to OPERABLE status.
.C. Required Action and C.1 6e in MODE 3. 6 hours associated Completion Time not met. AEl C.2 Be in MODE 5. 36 hours ,
q l 1
-l I
i O McGuire Unit 2 3.6-39 Supplement 2 l
I Centainment R: circulation Drains 3.6.15 g SURVEILLANCE REQUIREMENTS O SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.6.15.1 Verify, by visual inspection, that: Prior to entering MODE 4
- a. Each refueling canal drain valve is .from MODE 5 locked open; after each partial or
- b. Each refueling canal drain is not complete fill obstructed by debris; and of the canal SR 3.6.15.2 Verify, by visual inspection, that no 92 days debris is present in the upper compartment or refueling canal that could obstruct the refueling canal drain.
SR 3.6.15.3 Verify for each ice condenser floor drain 18 months that the:
- a. Valve opening is not impaired by ice, O b.
frost, or debris; Valve seat shows no evidence of damage;
- c. Valve opening force is s 66 lb; and
- d. Drain line from the ice condenser floor to the lower compartment is unrestricted.
I I g o l l McGuire Unit 2 3.6-40 Supplement 2
Reactor' Building t. 3.6.16-3;6 CONTAINMENT SYSTEMS'
.O 3.6.16 Reactor Building LCO 3.6.16. The reactor building shall be OPERABLE.
-APPLICABILITY: MODES.1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION- COMPLETION TIME
'A. Reactor building A.1 Restore reactor 24 hours.
inoperable, building to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AR(1 B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.16.1 Verify each door in each access opening is 31 days closed, except when the access opening is
.being used for normal transit entry and exit; then, at. least one (ksor shall be closed.
(continued) A
; r<
- McGuire. Unit ~2 3.6 Supplement 2 l
-Reactor Building 3.6.16 SURVEILLANCE FREQUENCY SR 3.6'.16.2_ Verify each Annulus' Ventilation' System 18 months on a train produces a pressure equal to or more STAGGERED TEST negative than -0.5 inch water gauge in the BASIS annulus within 22 seconds after a start signal and -3.5 inches water gauge after 48 seconds. Verifying that upon reaching a negative pressure of -3.5 inches water ;
gauge in the annulus, the' system switches into its recirculation mode of operation and that the time required for the annulus pressure to increase to -0.5 inch water gauge is a 278 seconds. SR 3.6.16.3 Verify reactor building structural 40 months integrity by performing a visual inspection of the exposed interior and exterior SQ surfaces of the reactor building. During shutdown for SR 3.6.1.1 Type A tests I O 3.6-42 Supplement 2 l McGuire Unit.2.
Containment' B 3.6.1 B 3.6' CONTAINMENT SYSTEMS B 3.6.1 Containment-
. BASES BACKGROUND- The containment is a free' standing steel pressure vessel surrounded by a reinforced concrete reactor building. The containment. vessel, including all.its penetrations, is a low leakage steel shell designed to contain the radioactive material that may be released from the reactor core following a design basis Loss of Coolant Accident (LOCA).
Additionally, the containment vessel and reactor building provide shielding from the fission products that may be . present in the containment atmosphere following accident conditions. The containment vessel is a vertical cylindrical steel pressure vessel with hemispherical dome and a flat circular base. It is completely enclosed by a reinforced concrete reactor building. An annular space exists between the walls and domes of the steel containment vessel and the concrete reactor building to provide for the collection, mixing, holdup, and controlled release of containment out leakage. Ice condenser containments utilize an outer concrete iO building for shielding and an inner steel containment for leak tightness. Containment piping penetration assemblies provide for the passage of process, service, sampling, and instrumentation pipelines into the containment vessel while maintaining containment integrity. The reactor building provides shielding and allows controlled release of the annulus atmosphere under accident conditions, as well as environmental missile protection for the containment vessel and Nuclear Steam Supply System. The inner steel containment and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment. SR 3.6.1.1 leakage rate requirements- comply with 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions. The isolation. devices for the penetrations in the containment boundary are a part of the containment leak
. (continued)
V . .
. McGuire Unit 1 B 3.6-1 Supplement 2 l p.
Centainment B 3.6.1 ,
' BASES O_
BACKGROUND tight barrier. To maintain this leak tight barrier: (continued)
- a. All penetrations required to be closed during accident conditions are either: 4
- 1. capable of being closed by an OPERABLE automatic containment isolation system, or
- 2. closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in LC0 3.6.3, " Containment Isolation Valves";
- b. Each air lock is OPERABLE, except as provided in l LC0 3.6.2, " Containment Air Locks";
- c. All equipment hatches are closed; and
- d. The sealing mechanism associated with a penetration (e.g., welds, bellows, or 0-rings) is OPERABLE.
APPLICABLE The safety design basis for the containment is that the (' g SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting Design Basis Accident (DBA) without exceeding the design leakage rates. The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures are a loss of coolant accident (LOCA) and a steam line break (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a LOCA. In the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.3% of containment air weight per day (Ref. 3). This leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in 10 CFR 50, Appendix J (Ref.1), as L,: the maximum allowable containment leakage rate at the calculated peak containment internal pressure (P,) resulting from the limiting design
-basis LOCA. The allowable leakage rate represented by L, forms the basis for the acceptance (continued) l McGuire Unit 1 B 3.6-2 Supplement 2
Centainment' B 3.6.1-- BASES' APPLICABLE. criteria imposed on all containment leakage rate testing. SAFETY ANALYSES L =is14.8 assumed to be 0.3% per actory da in the safety rate analysis (continued) P, psig (Ref. 3). Satis leakage test at results are a requirement for-the establishment of containment OPERABILITY. The containment satisfies Criterion 3 of 10 CFR 50.36 (Ref.4). LCO' Containment OPERABILITY is maintained by limiting leakage to s 1.0 L , except prior to the first startup after performing a requi, red 10 CFR 50, Appendix J, leakage test. At this time, the combined Type B and C leakage must be < 0.6 L., and the overall Type A leakage must be < 0.75 L,. Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis. Individual leaka lock (LCO 3.6.2)ge ratesvalves
, purge specified withfor the containment resilient seals, and air O reactor building bypass leakage (LCO 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 L,.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be
-OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.4, " Containment Penetrations."
n (continued)
<t McGuire Unit 1 B 3.6-3 Supplement 2 l
\
Centainment i: 3.6.1 BASES (continued) _! g) ACTIONS Ad 1 In the event containment is inoperable, containment must be { restored to OPERABLE status within 1 hour. The 1 hour l Completion Time provides a period of time to correct the d problem commensurate with the importance of maintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. B.1 and B.2 i If containment cannot be restored to OPERABLE status within I the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within ! 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly no ner and without challenging plant systems. SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance l with the visual examinations and Type A leakage rate test requirements of the Containment Leakage Rate Testing Program. Failure to meet specific leakage limits for the air lock, secondary containment bypass leakage path, and purge valve with resilient seals (as specified in LC0 3.6.2 and LC0 3.6.3) does not invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to overall Type A, B, and/or C leakage catses one of th(.-e overall leakage limits to be l exceeded. As left leakage prior to the first startup after l performing a required Containment Leakage Rate Testing l for overall l Program leakage Type A leakage test is required following toor an outage beshutdown
< 0.75 L,t hat included Type A testing. At all other times between required leakage ;
i I (continued) V ! l McGuire Unit 1 B 3.6-4 Supplement 2 l -m . .
Containment B 3.6.1 BASES SURVEILLANCE SR 3.6,1.1 (continued) REQUIREMENTS rate tests, the acceptance criteria is based on an overall Type A. leakage limit of s 1.0 L,. At s 1.0 L the offsite dose consequences are bounded by the assumpti,ons of the safety analysis. SR Frequencies are.as-required by the . Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in'the safety analysis. I The Surveillance is modified by a' Note which requires that the space between each dual-ply bellows assembly on i containment penetrations between the containment building and the annulus be vented to the annulus during each Type A test.
-l SR 3.6.1.2 Maintaining the Containment OPERABLE requires compliance with the Type B and C leakage rate test requirements of 10 CFR 50, Appendix J. Option A (Ref.1), as modified by approved exemptions. Failure to meet specific leakage O limits for the air lock, secondary containment bypass leakage path, and purge valve with resilient seals as specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to I TypeA, Band /orCleakagecausesoneoftheseoverall leakage limits to be exceeded. As left leakage prior to the first startup after performing a required 10 CFR 50, Appendix J, Option A, leakage test is required to be
< 0.6 L, for combined Type B and C leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overal? Type A leakage limit of s 1.0 L At s 1.0 L the offsite dose consequences are bounded'.by the assump,tions of the safety analysis. SR Frequencies are as required by Appendix J Option A, as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply. These periodic testing requirements verify that the containment leakage r:fe does Mt exceed the leakage rate assumed in the safety
- Elldlysi s.
(continued)
.McGuire Unit 1 B 3.6-5 Supplement 2 l
p ] I Centainment B 3.6.1: 4 BASES SURVEILLANCE .SR 3.6.1.2 (continued) REQUIREMENTS The Surveillance is modified by two Notes.- Note _1' requires that following each Type A-test, the space between each dual-ply bellows assembly be subjected to a low pressure leak test with no detectable. leakage. Otherwise, the assembly must be tested with the containment side of the bellows assembly pressurized to P, and meet the requirements of_SR 3.6.3.8 (bypass leakage requirements). Note 2 allows penetrations M372 and M373 to be tested without draining the glycol-water mixture from the associated diaphragm valves (NF-228A, NF-233B,. and NF-234A) as long as no. leakage is indicated. This test may be used in lieu of Section III.C.2(a) of 10 CFR_50, Appendix J. Option A which requires air. or nitrogen as the _ test medium. The required test pressure and interval are not changed. All test leakage rates shall be calculated using observed data converted.to absolute values. Error analysis shall also be performed to select a balanced integrated leakage measurement system. 1 l
.O REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Chapter 15.
- 3. UFSAR, Section 6.2.
- 4. 10 CFR 50.36. Technical Specifications, (c)(2)(ii).
i
;ll McGuire Unit 1 B 3.6 Supplement'2
-)
,, Containment Air Lecks B 3.6.2 B 3.6-- CONTAINMENT SYSTEMS' B 3.6.2, Containment Air Locks.
BASES BACKGROUND Containment air. locks form part of the containment pressure boundary and provide.a means for. personnel access during all MODES of. operation. Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to preventisimultaneous opening. During ' periods l when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of .; an air lock to remain open for extended periods when' frequent containment entry is necessary. Each air lock' door has been designed and tested to certify its ability to
. withstand a pressure in excess of the maximum' expected-pressure.following a Design Basis Accident.(DBA) in containment. As such. closure of a single door supports containment OPERABILITY. Each of the doors contains double inflatable seals and local-leakage rate testing capability to ensure pressure integrity.. To effect a leak tight seal, the air lock design uses pressure seated dcors (i.e., an increase in containment internal pressure results in
~O increased sealing force on each door). Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is-defeated. The containment air locks form part of the containment pressure boundary. - As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not maintaining air lock integrity or leak tightness may result , in a leakage rate in excess of that assumed in the unit safety analyses. (continued)
-McGuire Unit 1 > B 3.6 Supplement 2 l
+
...,j
Ccntainment Air Locks B'3.6.2-BASES ~(continued)
.fD t
v
-APPLICABLE The DBAs that result in a release of radioactive naterial SAFETY ANALYSES within containment are a loss of coolant accident and a rod ejection accident (Ref. 2). In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment' leakage. The containment was designed with an allowable leakage rate' of 0.3% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix 1 (Ref. 1),
l as L, = 0.30% of containment air weight per day, the maximum allowable containment leakage rate at the calculated peak
. containment. internal pressure P, = 14.8 psig following a DBA. This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air locks.
The containment air locks satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3). LC0 Each containment air lock forms part of the containment pressure boundary. As part of the containment pressure boundary, the air lock safety function is related to control O of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. - For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This ~ provision ensures.that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events.
~
Nevertheless, both doors are kept closed when the air lock _is not being used for. normal entry into or exit from containment. APPLICABILITY - In MODES 1,.2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the 1 , (continued) O 'l[McGuireUnit11 'B 3.6-8 Supplsment 2 I
.3
Containment Air Lecks B 3.6.2 BASES b APPLICABILITY probability and consequences of these events are reduced due (continued) to the pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the containment air locks during MODE 6 are addressed in LC0 3.9.4, " Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perfonn repairs on the affected air lock component. If the outer door is inoperabb, then it may be easily accessed for most repairs. It is preferred that the air l lock be accessed from inside primary containment by entering through the other OPERABLE air lock. However, if this is not practicable, or if repairs on either door must be performed from the barrel side of the door then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door). The ability to open the OPERABLE door, even if it means the containment boundary is temporarily not 3 intact, is acceptable due to the low probability of an event l that could pressurize the containment during the short time ) in which the OPERABLE door is expected to be open. After j each entry and exit, the OPERABLE door must be immediately closed. If ALARA conditions permit, entry and exit should be via an OPERABLE air lock. A second Note has been added to provide clarification that, , for this LCO, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions ) for each Condition provide appropriate compensatory actions j for each inoperable air lock. Complying with the Required 1 Actions may allow for continued operation, and a subsequent ) inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions. In the event the air lock leakage results in exceeding the overall containment leakage rate, Note 3 directs entry into the 6pplicable Conditions and Required Actions of LC0 3.6.1,
" Containment."
]
I (continued) C' , McGuire Unit 1 B 3.6-9 Supplement 2 l
Containment Air Locks l l B 3.6.2 BASES V ACTIONS A.1. A.2. and A.3 (continued) With one air lock door in one or more containment air locks inoperable, the OPERABLE door must be verified closed (Required Action A.1) in'each affected containment air lock. This ensures that a leak tight containment barrier is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour. This specified time period is consistent with the ACTIONS of LC0 3.6.1, which 1 requires containment be restored to OPERABLE status within 1 hour. In addition, the affected air lock penetration must be isolated by locking closed the OPERABLE air lock door within the 24 hour Completion Time. The 24 hour Completion Time is reasonable for locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained closed. Required Action A.3 verifies that an air lock with an inoperable door has been isolated by the use of a locked and closed OPERABLE air lock door. This ensures that an acceptable containment leakage boundary is maintained. The Completion Time of once per 31 days is based on engineering O judgment and is considered adequate in view of the low likelihood of a locked door being mispositioned and other administrative controls. Required Action A.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception of Note 1 does not affect tracking the Completion Time from the initial entry into Condition A; only the requirement to comply with the Required Actions. Note 2 allows use of the air lock for (continued)
' b/
l McGuire Unit 1. B 3.6-10 Supplement 2
)
Containment Air Locks ! B 3.6.2 ) BASES ACTIONS A.I. A.2. and A.3 (continued) entry and exit for 7 days under administrative controls if both air locks have an hoperable door. This 7 day restriction begins when the second air lock is discovered inoperable. Containment entry may be required on a periodic basis to perfonn Technical Specifications (TS) Surve111ances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e., non-TS-required activities) if the containment is entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is l acceptable due to the low probability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open. B.1. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Completion Times are consistent with those specified in O Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock). Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. (continued) b McGuire Unit 1 8 3.6-11 Supplement 2 l
Centainment Air Locks h B 3.6.2 s BASES ACTIONS C.1. C.2. and C.3
.(continued)
.With one or more air locks inoperable for reasons other than those described in Condition A or B, Required Action C.1 requires action to be initiated innediately to evaluate previous combined leakage rates' using current air lock test results. An evaluation is acceptable, since it is overly conservative to immediately declare the containment inoperable.if.both doors in an air lock have failed a seal-test or if the overall air lock leakage is not within ..
limits. .In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour (per-LCO 3.6.1) would be provided to restore the air lock door to
' OPERABLE status prior to requiring a plant shutdown. In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits.
Required Action C.2 requires that one door in the affected containment air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status within 1 hour. Additionally, the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock. D.1 and D.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within
~ 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
(continued) N-
.lcMcGuireUnit1 -- B 3.6-12 Supplement 2
Centainment Air Lecks B 3.6.2 O BASES (continued) b SURVEILLANCE SR 3.6.2.1 REQUIREMENTS Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of 10 CFR 50, Appendix J Option A (Ref. 1), as modified by approved exemptions. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by Appendix J, Option A (Ref. 1), as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply. The frequency required by 10 CFR 50 Appendix J. Option A, includes leak testing each door seal within 72 hours of closing or every 72 hours when entries are being made more frequently. The seal annulus leakage must be < 0.01 L determined by precision flow measurements when measure for$ as at least 30 seconds with the pressure between the seals g o P,. Overall airlock leakage tests are conducted at P, every ly 6 months. The overall air lock leakage rate must also be verified prior to establishing containment OPERABILITY. If the periodic 6-month test required Appendix J, Option A, is current, the seal leakage test may be substituted for the l full pressure test provided no maintenance has been ) performed on an air lock. Whenever maintenance has been I performed on an air lock, the requirements of paragraph III.D.2(b)(ii) of Appendix J Option A must still be met. This is an exemption from 10 CFR 50, Appendix J, Option A. The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidata the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of SR 3.6.1.2. This ensures that air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate. (continued) v. McGuire Unit 1 B 3.6-13 Supplement 2 l l l i
i Containment Air Locks B 3.6.2 O BASES V l SURVEILLANCE SR 3.6.2.2 REQUIREMENTS (continued) Door seals must be tested every 6 months to verify the integrity of the inflatable door seal. The measured leakage rate must be less than 15 standard cubic centimeters per minute (sccm) per door seal when the seal is inflated to approximately 85 psig. This ensures that the seals will remain inflated for at least 7 days should the instrument air supply to the seals be lost. The Frequency of testing is consistent with the overall airlock leakage tests required every 6 months by 10 CFR 50, Appendix J Option A (Ref. 1). l SR 3.6.2.3 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum ex)ected post accident containment pressure, closure of eitler door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock Os will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 18 months. The 18 month Frecuency is based on the need to perform this surveillance uncer the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the surveillance were performed with the reactor at power. The 18 month Frequency for the interlock is justified based on generic operating experience. The Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the interlock. REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
_n U l McGuire Unit 1 B 3.6-14 Supplement 2
1 l Centainment Isolation Valves ! B 3.6.3 B 3.6 CONTAINMENT SYSTEMS O- B 3.6.3 Containment Isolation Valves BASES BACKGROUND The contdament isolation valves form part of the containmat i:ressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. These isolation devices are either passive or active (automatic). Manual , valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves,'or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses. One of these barriers may be a closed system. These barriers (typically containment isolation valves) make up the Containment Q%J Isolation System. l Automatic isolation signals are produced during accident conditions. Containment Phase "A" isolation occurs upon receipt of a safety injection signal. The Phase "A" isolation signal isolates nonessential process lines in order to minimize leakage of fission product radioactivity. Containment Phase "B" isolation occurs upon receipt of a containment pressure High-High signal and isolates the remaining process lines, except systems required for accident mitigation. In addition to the Phase "A" isolation signal, the purge and exhaust valves receive an isolation signal on a containment high radiation condition. As a result, the containment isolation valves (and blind flanges) help ensure that the containment atmosphere will be isolated from the environment in the event of a release of fission product radioactivity to the containment atmosphere as a result of a Design Basis Accident (DBA). The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the ,s , (continued) ( McGuire Unit 1. B 3.6-15 Supplement 2 l
L 1 Containment Isolation alves B 3.6.3 BASES' BACKGROUND time: limits assumed in the safety analyses. Therefore, the (continued)_ OPERABILITY requirements provide assurance that the containment function assumed in the safety analyses will'be-maintained. Containment Purae System The Containment Purge System operates to supply outside air into the containment for ventilation and cooling or heating and nuy also be used to reduce the. concentration of noble gases within containment prior to and during personnel access. There are five_ purge air supply line penetrations and four exhaust penetrations in the containment. The supply penetrations include one line through the reactor building wall, two through the containment vessel into upper containment, and two lines through the containment vessel into lower containment. The exhaust penetrations include two lines through the containment vessel out of upper containment, one line through the containment vessel out of lower containment, and one line through the reactor building wall. Two normally closed isolation valves at each O containment vessel penetration provide containment isolation. The upper containment purge portion of the system has'the capability to operate when periods of sustained personnel access are required. This is allowed for normal operation (MODES 1-4), provided no more than one pair (one supply and one exhaust flow path) are open at one time. The upper containment supply and exhaust are also operated during refueling operation (MODES 5-6). The exhaust portion helps to reduce the consequences of a fuel handling accident in containment by removing and filtering any airborne radioactive effluents that may result from a fuel handling accident. The lower containment purge is only used during refueling operations because if these lines were used during normal operation, they may not close in the event of a LOCA. APPLICABLE: The containment isolation valve LC0 was derived from the SAFETY ANALYSES _ assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary (continued) l McGuire Unit:1 B 3.6-16 Supplement 2
Centainment Isolatio'n Valves B 3.6.3 BASES: APPLICABLE ' during major accidents. As part of the containment' SAFETY ANALYSES boundary, containment isolation valve OPERABILITY supports (continued)' leak tightness of the containment. Therefore, the safety analyses of any event requiring isolation of containment is applicable to this LCO. The'DBAs that result in a release of radioactive material within containment are a loss of coolant accident. (LOCA) and a rod ejection accident (Ref.1). In the analyses for each of these accidents, it is assumed that containment isolation. valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment isolation valves (including containment purge valves) are minimized. The safety analyses assume that the lower compartment and instrument room purge valves are closed at event initiation. The DBA analysis assumes that, within 76 seconds after the accident, isolation of the containment 1s complete and leakage terminated except for the design leakage rate, L..
'The containment isolation total response time of 76 seconds includes signal delay, diesel generator. startup (for loss of offsite power), and containment isolation valve stroke O times.
The single failure criterion required to be imposed in the conduct of plant safety analyses was considered in the original design of the containment purge valves. Two valves in series on each purge line provide assurance that both the supply and exhaust lines could be isolated even if a single failure occurred. The lower and instrument room purge valves may be unable to close in the environment following a LOCA. Therefore, each of the lower and instrument room purge valves is required to remain sealed closed during MODES 1,,2, 3, and 4. The upper . purge valves may be opened for ALARA considerations. In j this case, the single failure criterion remains applicable i to the containment purge valves due to failure in the r ntrol circuit associated with each valve. Again, the ' Jrge syst= valve design precludes a single failure from (continued) IMcGuire Unit 1 B 3.6-17 Supplement 2 l
)
C:ntainment Isolaticn Valves B 3.6.3 ,- BASES-V APPLICABLE compromising the containment boundary as long as the system SAFETY ANALYSES is operated in accordance with the subject LCO. (continued) The containment isolation valves satisfy Criterion 3 of 10 CFR 50.36 (Ref. 2). LCO Containment isolation valves form a part of the containment boundary. The containment isolation valves' safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA. The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The lower compartment and instrument room purge valves must be maintained sealed closed. The valves covered by this LC0 are listed along with their associated stroke times in the UFSAR (Ref. 3). The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are Q de-activated and secured in their closed position, blind V flanges are in place, and closed systems are intact. These passive isolation valves / devices are those listed in Reference 1. Purge valves with resilient seals and reactor building bypass valves must meet additional leakage rate requirements. The other containment isolation valve leakage rates are addressed by LCO 3.6.1, " Containment," as Type C testing. This LC0 provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required (continued) l McGuire Unit 1 B 3.6-18 Supplement 2
l Centainment Isolatien Valvas B 3.6.3
- BASES i
APPLICABILITY to be OPERABLE in MODE 5. The requirements for containment (continued) isolation valves during MODE 6 are addressed in LC0 3.9.4,
" Containment Penetrations."
ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, except for lower containment purge supply and exhaust valves for the lower compartment and instrument room, to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. For valve controls located in the control room, an operator may monitor containment isolation signal status rather than be stationed at the valve controls. Due to the size of the containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls. A single purge valve in a penetration flow path may be opened to effect repairs to an inoperable valve, as allowed by O SR 3.6.3.1. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions. The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. In the event the containment isolation valve leakage results in exceeding the overall containment leakage rate, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1. b
.a '
(continued) McGuire Unit 1 B 3.6-19 Supplement 2 l l,...... . . . . . . _ . . . .. . . . . . . .
Containment Isolaticn Valves B 3.6.3 BASES ACTIONS A.1 and A.2 (continued) .. _ In the event one containment isolation valve in one or more penetration flow paths is inoperable except.for purge valve or reactor building bypass leakage not within limit,'the affected penetration flow path must be isolated. The method of isolation must include the use of at least.one isolation . barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve inside containment with flow through the valve secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the' relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. Far affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required O Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required' Action does not require any testing or device manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those isolation devices outside i containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering.the fact that the devices are operated under administrative controls and the probability of their I misalignment is low. For the isolation devices inside i containment, the time period specified as " prior to entering i MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility. (continued)-
.lLMsGuireUnit1 B 3.6-20' Supplement 2
Containment Isolation Valves B 3.6.3 BASES-- ACTIONS A.1 and A.2 (continued) Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves. For penetration flow paths with only one containment isolation valve and a closed system, Condition C provides the appropriate actions. Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices once they have been verified to be in the proper position, is small. B.l With two containment isolation valves in one or more penetration flow paths inoperable, except for the purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated within O 1 hour. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour Completion Time is consistent with.the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in ! effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low. Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves. Condition A of this LCO (continued) McGuire Unit 1- B 3.6-21 Supplement 2 l l
Containment Isolaticn Valves B 3.6.3 p BASES U ACTIONS B.1 and B.2 (continued) addresses the condition of one containment isolation valve inoperable in this type of penetration flow path. C.1 and C.2 With one or more penetration flow paths with one containment isolation valve inoperable, the inoperable valve flow path must be restored to OPERABLE status or the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to isolate the affected penetration flow path. Required Action C.1 must be completed within the 72 hour Completion Time. The specified time period is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of maintaining containment integrity D during MODES 1, 2, 3, and 4. In the event the affected penetration flow path is isolated in accordance with Required Action C.1, the affected penetration flow path must be verified to be isolated on a periodic basis. This periodic verification is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low. Condition C is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with only one containment isolation valve and a closed system. The closed system must meet the requirements of Reference 5. This Note is necessary since this Condition is written to specifically address those penetration flow paths in a closed system. Required Action C.2 is modifiad by a Note that applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of (continued) w) l McGuire Unit 1 B 3.6-22 Supplement 2 l l
Centainment Isolatien Valvas B 3.6.3 BASES O ACTIONS C.1 and C.2 (continued) administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. D.d With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours. Restoration can be accomplished by isolating the penetration (s) that caused the limit to ha exceeded by use of one closed and de-activated automauc valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If twa isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 4 hour Completion Time is reasonable considering the f time required to restore the leakage by isolating the penetration (s) and the relative importance of secondary containment bypass leakage to the overall containment function. E.1. E.2. and E.3 i In the event one or more purge valves for upper and lower containment or instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of I isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a ; closed and de-activated automatic valve, closed manual ' valve, or blind flange. A valve with resilient seals utilized to satisfy Required Action E.1 must have been demonstrated to meet the leakage requirements of SR 3.6.3.6. l The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist. (continued) V - McGuire Unit 1 B 3.6-2S Supplement 2 l 1
Containment Isolaticn Valves B 3.6.3 BASES b] ACTIONS E.1. E.2. and E.3 (continued) In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility. For the containment purge valve with resilient seal that is j l isolated in accordance with Required Action E.1, SR 3.6.3.6 \ must be performed at least once every 92 days. This assures that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must te brought to a MODE in which the , LCO does not apply. To a:hieve this status, the plant must J be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly nenner and without challenging plant systems. (/ . (continued) l McGuire Unit 1 B 3.6-24 Supplement 2
Centainment Isolaticn Valves - B 3.6.3 BASES (continued) V SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge valve for the lower compartment and. instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been performed. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term " sealed" has no connotation of leak tightness The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), I related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance pern11ts opening one purge valve in a penetration flow path to perform repairs. I SR 3.6.3.2 I l This SR ensures that the containment purge supply and exhaust isolation valves for the upper compartment are closed as required or, if open, open for an allowable reason. If a valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, . it is not considered to have leakage outside of limits. The . SR is not required to be met when the valves are open for l the reasons stated. The valves may be opened for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements' discussed in SR 3.6.3.3. (continued) McGuire Unit 1 B 3.6-25 Supplement 2 l l 1
Containment Isolation Valves B 3.6.3 BASES (continued) v l SURVEILLANCE SR 3.6.3.3 REQUIREMENTS (continued) This SR requires verification that each containment isolation manual valve and blind flange located outside l containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. l SR 3.6.3.4 This SR requires verification that each containment isolation manual valve and blind flange located inside l containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the O (continued) 'Y l McGuire Unit 1- B 3.6-26 Supplement 2
Ccntainment Isolatien Valves B 3.0.3 A BASES (continued) U SUPNEILLANCE SR 3.6.3.4 (continued) REQUIREMENTS Frequency of " prior to entering MODE 4 from MODE 5 if not
. performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of. their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing.
This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. V SR 3.6.3.5 l Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time-is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program. SR 3.6.3.6 l For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, is required to ensure OPERABILITY. The measured leakage rate for containment purge lower compartment and instrument room valves must be s 0.05 L, when pressurized to P,. The measured leakage rate for containment purge upper compartment valves must be s 0.01 L, when pressurized to P,. Operating experience has A (continued) N.) McGuire Unit 1 B 3.6-27 Supplement 2 l l J
' Containment Isolatien Valves B 3.6.3. ,
- BASES ((continued)
SURVEILLANCE ~ SR 3.6.3.6 (continued) REQUIREMENTS demonstrated.that this type of seal has the potential to degrade in a shorter time period than do other seal types'. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment) a Frequency of 184 days was established. The containment purge upper compartment valves may be used-
' during normal operation, therefore, in addition to the 184 day Frequency, this SR must be performed every 92 days after opening the valves. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is: a prudent measure after a valve has been opened. The containment purge lower compartment valves and instrument room valves remain closed during normal operation and this SR is only performed every 184 days for these valves.
.l SR 3.6.3.7' Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A. Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Opersting experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
m (continued) l lMcGuire Unit 1: B 3.6 Supplement 2 ; p
~
. . . . . , , l
I Ccntainment Isolation Valves B 3.6.3 p BASES (continued) V SURVEILLANCE SR 3.6.3.8 l REQUIREMENTS-(continued) This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate. This provides assurance that the assumptions in the safety analysis are met. The leakage rate of each bypass leaka maximum pathway leakage (gethrough leakage path isthe assumed worse oftothe be the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser-leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J m6ximum pathway leakage limits are to be quantified in accordance with Appendix J). Penetrations which are not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurized during SR 3.6.1.1 Type A testing. The Frequency for penetrations which are individually testable is required C by 10 CFR 50, Appendix J as modified by approved exemptions (and therefore, the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J Type B or C l test. This SR simply imposes additional acceptance criteria. Bypass leakage is considered part of L,. i REFERENCES 1. UFSAR, Section 15.
- 2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 3. UFSAR, Section 6.2.
- 4. Generic Issue B-24.
- 5. Standard Review Plan 6.2.4 McGuire Unit 1- B 3.6-29 Supplement 2 l
Centainment Prassure B 3.6.4-B 3.6 CONTAINMENT SYSTEMS B 3.6.4- Containment Pressure BASES BACKGROUND The' containment pressure is limited during'nonnal operation to preserve the initial conditions assumed in the accident analyses for a loss of coolant accident (LOCA)-or steam line break (SLB). These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere following an event which has the potential to result in a net external pressure on-the containment. Containment pressure is a process variable that is monitored and controlled. The containment pressure limits are derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis. Should operation occur outside these limits coincident with a Design Basis Accident (DBA), post accident containment pressures could exceed calculated values. APPLICABLE Containment internal pressure is an initial condition used SAFETY ANALYSES in the DBA analyses to establish the maximum peak containment internal pressure. The limiting DBAs considered, relative to containment pressure, are the LOCA and SLB, which are analyzed using. computer codes designed to predict the resultant containment pressure transients. The worst case LOCA generates larger mass and energy release than the worst case SLB. Thus, the LOCA event bounds the SLB event from the containment peak pressure standpoint (Ref. 1). The initial pressure condition used in the containment i analysis was 15.0 psia (0.3 psig). The containment analysis (Ref.1) shows that the maximum peak calculated containment pressure, P., results from the limiting LOCA. The maximum containment pressure resulting from the worst case LOCA does not exceed the containment design pressure 15.0 psig. _ (continued) f-( .- l
- l . McGuire Unf t 1 B 3.6-30 Supplement 2 l
Containment Prsssuro B 3.6.4 BASES
.g V
APPLICABLE The containment was also designed for an external pressure SAFETY ANALYSES load equivalent to -1.5 psig. (continued) There are four conditions which have a potential for resulting in a net external pressure on the containment:
- 1. Rupture of a hot or high pressure process pipe in the annulus.
- 2. Inadvertent Containment Spray System initiation during normal operation.
- 3. Inadvertent containment air return fan initiatior, during normal operation.
- 4. Containment purge fan operation with containment purge inlet valves closed.
The containment design of 1.5 psig negative is not violated in the above conditions due to either equipment limitations or design features. For certain aspects of transient accident analyses, p Q maximizing the calculated containment pressure is not conservative. In particular, the cooling effectiveness of the Emergency Core Cooling System during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. Therefore, for the reflood phase, the containment backpressure is calculated in a manner designed to conservatively minimize, rather than maximize, the containment pressure response in accordance with 10 CFR 50, Appendix K (Ref. 2). Containment pressure satisfies Criterion 2 of 10 CFR 50.36 (Ref.3). LC0 Maintaining containment pressure at less than or equal to the LC0 upper pressure limit ensures that, in the event of a DBA, the resultant peak containment accident pressure will remain below the containment design pressure. Maintaining containment pressure at greater than or equal to the LCO g (continued) U McGuire Unit 1 B 3.6-31 Supplement 2 l
Containment Pressure B 3.6.4-BASES v] LC0 lower pressure limit ensures that the containment will not (continued) exceed the design negative differential pressure following an event which has the potential to result in a net external pressure on the containment. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. Since maintaining containment pressure within limits is essential to ensure initial conditions assumed in the accident analyses are maintained, the LC0 is applicable in MODES 1, 2, 3 and 4. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment pressure within the limits of the LC0 is not required in MODE 5 or 6. ACTIONS L_1.
^
When containment pressure is not within the limits of the LCO, it must be restored to within these limits within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis. The I hour Completion Time is consistent with the ACTIONS of LC0 3.6.1, " Containment," which requires that containment be restored to OPERABLE status within 1 hour. < l l B.1 and B.2 l If containment pressure cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
,- y (continued)
-( ) l McGuire Unit 1 B 3.6-32 Supplement 2 l l
1 Containment Pressure B 3.6.4 BASES'(continued)- SURVEILLANCE' SR 3.6.4.1 REQUIREMENTS. Verifying that containment pressure is within limits ensures that unit operation remains within the limits assumed in the containment analysis. The 12 hour Frequency of this SR was developed based on-operating experience related to trending of containment pressure variations during the applicable MODES. Furthermore, the 12 hour Frequency is considered adequate in view of other ir,dications available in the control room, including alarms, to alert the operator to an abnormal containment pressure condition.
. REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50, Appendix K.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
O i I
) .f E McGuire Unit l' B 3.6-33 Supplement 2 l
{
)
,1
' Containment Air Temp:rature B 3.6.5-B 3.6 CONTAINMENT SYSTEMS B 3.6.5 Containment Air Temperature-BASES BACKGROUND The containment structure serves to contain radioactive -
. material that may be released from the reactor core following a Design Basis Accident (DBA). The. containment average air temperature is limited, during normal operation, ;
to preserve the initial conditions assumed in the accident ' analyses for a loss of coolant accident (LOCA) or steam line break (SLB). The containment average air temperature limit is derived from the input conditions used in the containment functional analyses and the containment structure external pressure analyses. This LCO ensures that initial conditions assumed in the analysis of containment response to a DBA are not violated during unit operations. The total amount of energy to be removed from containment by the Containment Spray and ECCS systems during post accident conditions is dependent upon the energy released to the containment due to the event, as well as the initial containment temperature and pressure. High initial temperature, results in a higher O peak containment. temperature. Low initial temperature results in a higher peak containment pressure. Exceeding ' containment design pressure may result in leakage greater. than that assumed in the accident analysis. Operation with containment temperature in excess of the LCO limit violates an initial condition assumed in the accident analysis. APPLICABLE Containment average air temperature is an initial condition SAFETY ANALYSES used in the DBA analyses that establishes the containment environmental qualification operating envelope for both pressure and temperature. The limit for containment average a air temperature ensures that operation is maintained within
, the assumptions used in the DBA analyses for containment (Ref.1),
(continued) O ll McGuireLUnit 1 B 3.6-34 Supplement 2 ~
-j
Centainment Air Temp 3rature-B 3.6.5' _j BASES'
.O APPLICABLE' The limiting DBAs considered relative to containment SAFETY: ANALYSES OPERABILITY are the LOCA and SLB.. The DBA LOCA and SLB are (continued) analyzed using computer codes. designed to predict the-resultant containment pressure and' temperature transients.
No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs-are analyzed with regard to Engineered Safety Feature (ESF) systems, assuming the loss of one ESF bus, which is the worst case single active failure, resulting in~one train each of Containment Spray. System, Residual Heat Removal System, and Air Return System being rendered' inoperable. The limiting DBA for the maximum peak containment air temperature is an SLB. For the upper. compartment, the , initial containment average air temperature assumed in the design basis analyses (Ref. 1) is 100*F. For the lower compartment, the initial average containment air temperature assumed in the design basis analyses is 135'F. This resulted in a maximum containment air temperature of 317'F. The current environmental qualification temperature limit is 341'F. The temperature upper limits are used to establish the environmental qualification operating envelope' for both O ' containment compartments. The maximum peak containment air temperature for both containment compartments was calculated to be within the current environmental qualification temperature limit during the transient. The basis of the-containment environmental qualification temperature is to ensure the performance of safety related equipment inside containment (Ref. 2). l The temperature upper limits are also used in the depressurization analyses to ensure that the minimum pressure limit is maintained for both containment 4 compartments following an event which has the potential to result in a net external pressure on the containment. , The containment pressure transient is sensitive to the initial air mass in containment and, therefore, to the initial containment air temperature. The limiting DBA for establishing the maximum peak containment internal pressure 1 (continued)- L) lMcGuireUnitl' B 3.6-35 Supplement 2. 'l
Containment-Air Temperaturc' B 3.6.5~ l l BASES- ;
-APPLICABLE is a LOCA. The . temperature lower limits, 70*F for the upper SAFETY ANALYSES- compartment and 100*F for the lower compartment, are used in (continued) this analysis to ensure that, in _the event of an accident, the maximum containment internal pressure will not be exceeded in either containment compartment.
Containment average air temperature satisfies Criterion 2 of 10 CFR 50.36 (Ref. 3). LCO During a DBA, with an initia1' containment average air temperature within the LCO temperature limits, the resultant ; peak accident temperature is maintained below the .. I containment environmental qualification temperature. As a result, the ability of containment to perform its design function is ensured. Two Notes to the LCO provide containment air temperature flexibility. Note 1 establishes that in MODES 2, 3, and 4, containment air temperature may be as low as 60*F because the resultant calculated peak j containment accident pressure would not exceed the design j pressure due to a lesser amount of energy released from the pipe break in these MODES. Note 2 allows the containment lower compartment temperature to be between 120 and 125'F O for up to 90 cumulative days per calendar year provided the lower compartment temperature average over the previous 365 days is less than 120*F. Within this 90 cumulative day period, lower compartment temperature may be between 125'F and 135'F for 72 cumulative hours. These exceptions are necessary during peak lake temperature periods when service water temperatures increase. A failure of a containment air handling unit concurrent with peak service water temperatures could. exceed the normal lower compartment , temperature limit. The exception provides a limited period I of time to effect repairs and avoid a forced unit shutdown. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of l radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperature within the limit is not. required in MODE 5 or 6.
~
o (continued)
'l'McGuireUnit1 B 3.6-36 Supplement 2 o
j: h..
t Ccntainment Air Temperature B 3.6.5
- g. BASES ACTIONS Ad When containment average air temperature in the upper or lower compartment is not within the limit of the LCO, the average air temperature in the affected compartment must be restored to within limits within 8 hours. This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.
B.1 and B.2 If the containment average air temperature cannot be restored to within its limits within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
'% I SURVEILLANCE SR 3.6.5.1 and SR 3.6.5.2 .
REQUIREMENTS Verifying tnat containment average air temperature is within the LC0 limits ensures that containment operation remains within the limits assumed for the containment analyses. In order to determine the containment average air temperature, a weighted average of ambient air temperature monitoring stations is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere. The weighted average is the sum of each temperature multiplied by its respective containment volume fraction. In the event of , inoperative temperature sensor (s), the weighted average j shall be taken as the reduced total divided by one minus the volume fraction represented by the sensor (s) out of service. The upper compartment measurements should be taken at elevation 826 feet at the inlet of each upper containment ventilation unit. The lower compartment measurements should be taken at elevation 745 feet at the inlet of each lower j i (continued) i V McGuire Unit 1 B 3.6-37 Supplement 2 l l
I Centainment Air Temperature B 3.6.5 BASES SURVEILLANCE SR 3.6.5.1 AND SR 3.6.5.2 (continued) ) REQUIREMENTS. ) containment ventilation unit.- The 24 hour Frequency is l considered adequate in view of other indications available { in the control room, including alarms, to alert the operator l to an abnormal containment temperature condition. I REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.49.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
l l O O l McGuire Unit 1 B 3.6-38 ' Supplement 2
Centainment Spray System i. B 3.6.6 l l(-) B 3.6 CONTAINMENT SYSTEMS
]l
'V B 3.6.6 Containment Spray System BASES l 4
- BACKGROUND The Containment Spray System provides containment atmosphere cooling to limit post accident pressure and temperature in containment to less than the design values. Reduction of 4 containment pressure and the iodine removal capability of the spray reduce the release of fission product radioactivity from containment to the environment,-in the event of a Design Basis Accident (DBA). The Containment Spray System is designed to meet the requirements of 10 CFR 50, Appendix A, GDC 38, " Containment Heat Removal,"
GDC 39, " Inspection of Containment Heat Removal Systems," GDC 40, " Testing of Containment Heat Removal Systems," GDC 41, " Containment Atmosphere Cleanup," GDC 42,
" Inspection of Containment Atmosphere Cleanup Systems," and GDC 43, " Testing of Containment Atmosphere Cleanup Systems" (Ref. 1). ;
I The' Containment Spray System consists of two separate trains a of equal capacity, each capable of meeting the system design ] basis spray coverage. . Each train includes a containment > fO spray pump, one containment spray heat exchanger, spray headers, nozzles, valves, and piping. Each train is powered I from a separate Engineered Safety Feature (ESF) bus. The i refueling water storage tank (RWST) supplies borated water to the Containment Spray System during the injection phase of operation. In the recirculation mode of operation, containment spray pump suction is transferred from the RWST to the containment recirculation sump (s). The diversion of a portion of the recirculation flow from each train of the Residual Heat Removal (RHR) System to additional redundant' spray headers completes the Containment Spray System heat removal capability. Each RHR train is capable of supplying spray coverage, if required, to supplement the Containment Spray System. l l l (continued) McGuire Unit 1 B 3.6-39 Supplement 2 l
4 Ccntainment Spray System [ B 3.6.6 BASES BACKGROUND.. The Containment Spray System and RHR System provide a spray (continued) of cold or subcooled borated water into the upper ) containment volume to limit the containment pressure and temperature during a DBA. The.RWST solution temperature is ] an important factor in determining the heat removal capability of the Containment Spray System during the injection phase. In the recirculation mode of operation, heat is removed from the containment sump water by the Containment Spray Systein and RHR heat exchangers. Each train of the Containment Spray System, supplemented by a train of RHR spray, provides adequate spray coverage to meet the system design requirements for containment heat removal. For the hypothetical double-ended rupture of a Reactor i Coolant System pipe, the pH.of the sump solution (and, I consequently, the spray solution) is raised to at least 8.0 I within one hour of the onset of the LOCA. It is possible to adjust the pH of the sump solution using the chemical mixing , tank and the charging pumps, should it become necessary. l The alkaline pH of the containment sump water minimizes the I evolution of iodine and the occurrence of chloride and j caustic stress corrosion on mechanical systems and i components exposed to the fluid. The Containment Spray System is actuated either automatically by a containment pressure high-high signal or manually. An automatic actuation opens the containment 1 spray pump discharge valves, starts the two containment spray pumps, and begins the injection phase. A manual t actuation of the Containment Spray System requires the operator to actuate two separate train related switches on the main control board to begin the same sequence of two train actuation. The injection phase continues until an RWST level Low-Low alarm is received. The Low-Low alarm for the RWST signals the operator to manually align the system to the recirculation mode. The Containment Spray System in the recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the operator in accordance with the emergency operation procedures. (continued) l McGuire Unit 1 8 3.6-40 Supplement 2
Centainment Spray System i B 3.6.6 ! l f - BASES iD V BACKGROUND The RHR spray operation is initiated manually, when required (continued) by the emergency operating procedures, after the Emergency Core Cooling System (ECCS) is operating in the recirculation mode. The RHR sprays are available to supplement the Containment Spray System, if required, in limiting conta!nment pressure. This additional spray capacity would typically be used after the ice bed has been depleted and in the event that containment pressure rises above a predetermined limit. The Containment Spray System is an ESF system. It is designed to ensure that the heat removal capability required during the post accident period can be attained. The operation of the Containment Spray System, together with the ice condenser, is adequate to assure pressure suppression subsequent to the initial blowdown of steam and water from a DBA. During the post blowdown period, the Air Return System (ARS) is automatically started. The ARS returns upper compartment air through the divider barrier to the lower compartment. This serves to equalize pressures in containment and to continue circulating heated air and steam I through the ice condenser, where heat is removed by the j remaining ice. i n l 'd The Containment Spray System limits the temperature and I pressure that could be expected following a DBA. Protection of containment integrity limits leakage of fission product radioactivity from containment to the environment. I APPLICABLE The limiting DBAs considered relative to containment SAFETY ANALYSES OPERABILITY are the loss of coolant accident (LOCA) and the steam line break (SLB). The DBA LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients. No two l DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed, in regard to containment ESF systems, assuming the loss of one ESF bus, which is the worst case single active failure, resulting in one train of the Containment Spray System, the RHR System, and the ARS being rendered inoperable (Ref. 2). The DBA analyses show that the maximum peak containment i pressure results from the LOCA analysis, and is calculated I to be less than the containment dr. sign pressure. The p) v (continued) McGuire. Unit 1 B 3.6-41 Supplement 2 l l
Containment Spray System B 3.6.6 BASES' O V APPLICABLE maximum peak containment atmosphere temperature results SAFETY. ANALYSES from the SLB analysis and was calculated to be within the (continued) containment environmental qualification temperature during the DBA SLB. The basis of the containment environmental qualification temperature is to ensure the OPERABILITY of safety related equipment inside containment (Ref. 3). The modeled Containment Spray System actuation from the containment analysis is based on a response time associated with exceeding the containment pressure high-high signal setpoint to achieving full flow through the containment spray nozzles. - A delayed response time initiation provides conservative analyses of peak calculated containment temperature and pressure responses. The Containment Spray System total response time of 45 seconds is composed of signal delay, diesel generator startup, and system startup time. For certain aspects of transient accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the ECCS cooling effectiveness during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For these q calculations, the containment backpressure is calculated in C/ a manner designed to conservatively minimize, rather than maximize, the calculated transient containment pressures in accordance with 10 CFR 50, Appendix K (Ref. 4). Inadvertent actuation is precluded by design features consisting of an additional set of containment pressure sensors which prevents operation when the containment' pressure is below the containment pressure control system permissive. 1 Containment Spray System satisfies Criterion 3 of CFR 50.36 (Ref. 5). (continued) l'.McGuirel Unit 1 B 3.6-42 Supplement 2~
a Containment Spray System B 3.6.6 BASES ~(continued) b LC0 During a DBA, one train of Containment Spray System is required to provide the heat removal capability assumed in the_ safety analyses. To ensure that this requirement is met, two containment spray trains must be OPERABLE with power from two safety related, independent power supplies. Therefore, in the event of an accident, at least one train operates. Each Containment Spray System includes a spray pump, headers, valves, heat exchangers, nozzles, piping. instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon an ESF actuation signal and manually transferring suction to the containment sump. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the Containment Spray System. In MODES 5 and 6, the probability and consequences of these events are reduced because of the pressure and temperature ( 'Q) limitations of these MODES. Thus, the Containment Spray System is not required to be OPERABLE in MODE 5 or 6. ACTIONS L1 With one containment spray train inoperable, the affected train must be restored to OPERABLE status within 72 hours. The components in this degraded condition are capable of providing 100% of the heat removal after an accident. The 72 hour Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period. (continued) g) .k. { McGuire Unit 1 B 3.6-43 Supplement 2 l j 1 I i
Centainment Spray System B 3.6.6 BASES ACTIONS B.1 and B.2 (continued) If the affected containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 84 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. O This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those valves outside containment and capable of potentially being mispositioned, are in the correct position. SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by Section XI of the ASME Code (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend (continued)
\..)
l McGuire Unit 1 B 3.6-44 Supplement 2
- q l
Centainment Spray System B 3.6.6 BASES SURVEILLANCE- SR 3'.6.6.2 (continued) REQUIREMENTS performance, and. detect incipient failures by indicating-abnonnal performance. The Frequency of this SR is in accordance with the Inservice Testing Program. SR 3.6.6.3'and SR 3.6.6.4 These SRs require verification that each automatic containment spray valve actuates to its correct position and each containment spray pump starts upon receipt of an actual or simulated Containment Pressure High-High signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. .The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillances when perfonned at the 18 month Frequency. Therefore, the Frequency was concluded to be. acceptable from a reliability standpoint. The. surveillance of containment sump isolation valves is also required by SR 3.6.6.3. A single surveillance may be used to satisfy both requirements. SR 3.6.6.5 and SR 3.6.6.6 j These SRs require verification that each containment spray pump discharge valve opens or is prevented from opening and each containment spray pump starts or is de-energized and prevented from starting upon receipt of Containment Pressure j Control System start and terminate signals. The CPCS is 1 described in the Bases for LCO 3.3.2, "ESFAS." The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage. (continued) McGuire Unit ~1- ^B 3.6-45 Supplement 2 l 2_ _ __ w__+__.
Centainment Spray System
.B 3.6.6
-BASES
' SURVEILLANCE SR 3.6.6.7.
' REQUIREMENTS
-With the containment spray inlet valves closed and'the spray
.(continued) header drained of any solution, low pressure air or smoke '
can be blown through test connections. - The spray nozzles can also be periodically tested using a vacuum blower to: induce air. flow through each nozzle to verify unobstructed flow. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident 'is not degraded. Because of the passive
' design of the nozzle, a test at 10 year intervals is considered adequate to detect obstruction of the spray.
nozzles. REFERENCES 1. 10 CFR 50, Appendix A GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.49.
- 4. 10 CFR~50, Appendix K.
- 5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 6. ASME, Boiler and Pressure Vessel Code, Section XI.
i i p (continued) iY. l..McGuireUnit1- .B 3.6-46 Supplement 2
Hydrog:n Rtcombiners B 3.6.7 .
.1 B 3.6'~ CONTAINMENT SYSTEMS B 3.6.7 Hydrogen Recombiners BASES 1 BACKGROUND. The function of the hydrogen recombiners is to eliminate the potential breach of cortainment due to a hydrogen oxygen reaction.
Per 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light-Water-Cooled _ Reactors" (Ref. 1), and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2), hydrogen recombiners are required to reduce the hydrogen concentration in the containment following a loss'of coolant accident (LOCA). The recombiners accomplish this by recombining hydrogen and oxygen to form water vapor. The vapor remains in containment, thus eliminating any discharge to the environment. The hydrogen recombiners are manually initiated since flaninable limits would not be reached until several. days after a Design Basis Accident (DBA). Two 100% capacity independent hydrogen recombiner systems are provided. Each consists of controls located outside g containment in an area not exposed to the post LOCA environment, a power supply and a recombiner. Recombination is accomplished by heating a hydrogen air mixture above. 1150"F. The resulting water vapor and discharge gases are cooled prior to discharge from the recombiner. A single recombiner is capable of maintaining the hydrogen concentration in containment below the 4.0-volume percent (v/o) flaninability limit. Two recombiners are provided to meet the requirement for redundancy and independence. Each recombiner is powered from a separate Engineered Safety Features bus, and is provided with a separate power panel and control panel.
)
(continued)
-McGuire Unit 1 B 3.6-47 Supplement 2 l l
_a
Hydrogen Rtcombin2rs-
'B 3.6.7-
~ BASES
' APPLICABLE- The hydrogen recombiners provide for the capability of SAFETY ANALYSES controlling the bulk hydrogen concentration in containment -1 to less' than-the lower flamable concentration of 4.0 v/o. l following a DBA. This control would prevent a containment, wide hydrogen burn, thus ensuring the pressure and temperature assumed in the. analyses are not exceeded. The limiting DBA relative to hydrogen generation is a LOCA.
Hydrogen may accumulate in containment following a LOCA'as'a result of:
- a. A metal steam reaction between the zirconium' fuel rod cladding and the reactor coolant;
- b. Radiolytic decomposition of water in the Reactor-Coolant System (RCS) and the containment sump;
- c. Hydrogen in the RCS at the time of the LOCA (i.e.,
hydrogen dissolved in the reactor coolant and hydrogen gas in the pressurizer vapor space); or
- d. Corrosion of metals exposed to containment spray and Emergency Core Cooling System solutions.
To evaluate the potential for hydrogen accumulation in O containment following a LOCA, the hydrogen generation as a , function of time following the initiation of the accident is calculated. Conservative assumptions recon 1 mended by Reference 3 are used to maximize the amount of hydrogen calculated. Based on the conservative assumptions used to calculate the hydrogen concentration versus time after a LOCA, the hydrogen concentration increases at different rates depending on the region of the containment being measured. The initiation of the Air Return System and Hydrogen Skinner System along with the hydrogen recombiners will maintain the hydrogen concentration in the primary containment below flammability limits. The hydrogen recombiners are designed such that, with the conservatively calculated hydrogen generation rates, a single recombiner is capable of limiting the peak hydrogen concentration in containment to less than 4.0 v/o (Ref. 3). The hydrogen recombiners satisfy Criterion 3 of 10 CFR 50.36 (Ref.4).
'(continued)'
(l}McGuireUnit1 B 3.6-48 Supplement 2
=__ = _ _
Hydrogin Recombin::rs B 3.6.7
' BASES (continued)
LCO' . Two hydrogen recombiners must be OPERABLE. This ensures operation of at least-one hydrogen recombiner in the event of a_ worst. case single active failure.
, . Operation with at least one hydrogen recombiner ensures that j the post LOCA hydrogen concentration can be prevented from exceeding the flammability limit.
APPLICABILITY In MODES 1 and 2, two hydrogen recombiners are required to control the hydrogen concentration within containment below its flaninability limit of 4.0 v/o following a LOCA, assuming a worst case single failure. In MODES 3 and 4, both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the DBA LOCA. Also, because of the limited time in these MODES, the probability of an accident requiring the hydrogen recombiners is low. ' Therefore, the hydrogen recombiners are not required in MODE 3 or 4. In MODES 5 and 6, the probability and consequences of a LOCA are low, due to the pressure and temperature limitations in O these MODES. Therefore, hydrogen recombiners are not required in these MODES. ACTIONS Ad With one containment hydrogen recombiner inoperable, the inoperable recombiner must be restored to OPERABLE status within 30 days.- In this condition, the remaining OPERABLE hydrogen recombiner is adequate to perform the hydrogen control function. 'However, the overall reliability is reduced because a single failure in the OPERABLE recombiner could result in reduced hydrogen control capability. The 30 day Completion Time is based on the availability of. the other hydrogen recombiner, the small probability of a LOCA occurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a LOCA (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit. (continued)
' McGilire Unit 1 .B 3.6-49 Supplement 2 l l
1 o
Hydrogen Rscombiners - B 3.6.7.
- BASES ACTIONS. M '(continued)
' Required Action A.1 has been modified.by a Note that states the provisions of LC0 3.0.4 are not applicable. As a result, a MODE change is allowed when one recombiner is inoperable. This allowance is based on the~' availability of-the other hydrogen recombiner, the small probability of a LOCA occurring (that would generate an amount of hydrogen that exceeds the flamability limit), and the amount of time available' after a LOCA (should one occur) for. operator.
action to prevent hydrogen accumulation from exceeding the flammability limit. M If the inoperable hydrogen recombiner(s) cannot be restored to OPERABLE. status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. O SURVEILLANCE SR 3.6.7.1 REQUIREMENTS Performance of a system functional test for each hydrogen recombiner ensures the recombiners are operational and can attain and sustain the temperature necessary for hydrogen recombination. In particular, this SR verifies that the minimum heater sheath temperature increases to a 700*F in s 90 minutes. After reaching 700*F, the power is increased to msximum power for approximately 2 minutes and power is verified to be a 60 kW. Industry operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
, _(continued)
&p .
. l McGuire Unit 1 B 3.6-50 Supplement 2 -
Hydrogan R:combin:rs B 3.6.7-l. BASES SURVEILLANCE SR 3.6.7.2 REQUIREMENTS
- (continued) This SR ensures there are no physical problems ~that could affect recombiner operation. Since-the recombiners are mechanically passive, they are not subject to mechanical failure. The only credible failure involves loose wiring or.
structural connections, deposits of foreign materials, etc. A visual inspection is sufficient to detennine abnormal'. conditions that could cause such failures. The 18 month Frequency for this SR was developed considering the incidence of hydrogen recombiners failing the SR in the past is low. SR 3.6.7.3 i This SR requires performance of~ a resistance to ground test for each heater phase to ensure that there are no detectable grounds in any heater phase. This SR should be performed following SR 3.6.7.1. This is accomplished by verifying that the resistance to ground for any heater phase is it 10,000 ohms. The 18 month Frequency for this Surveillance was developed considering the incidence of hydrogen recombiners failing the SR in the past is low. REFERENCES 1. 10 CFR 50.44.
- 2. 10 CFR 50, Appendix A, GDC 41.
- 3. UFSAR Section 6.2.
- 4. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- McGuire Unit li B 3.6-51 Supplement 2 l
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..ag .ps
7 HSS.
~B 3.6.8-
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B 3.6 CONTAINMENT SYSTEMS O BL3.6.8 Hydrogen Skimer System (HSS)
' BASES 1
~ BACKGROUND ' The HSS reduces the potential for breach of containment due to a hydrogen oxygen reaction by providing a uniformly mixed post accident containment atmosphere, thereby minimizing the.
potential for local hydrogen burns due to a pocket of hydrogen above the flamable concentration. Maintaining a uniformly mixed containment atmosphere also ensures that the hydrogen monitors will give an accurate measure of the bulk hydrogen concentration and give the operator the capability of preventing the occurrence of a bulk hydrogen burn inside containment per 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors" (Ref. 1), and 10 CFR 50, GDC 41. " Containment Atmosphere Cleanup" (Ref. 2). l The post accident HSS is an Engineered Safety Feature (ESF) and is. designed to withstand a loss of coolant accident (LOCA) without loss of function. The System has two independent trains,.each consisting of two fans with.their own motors and controls. Each train is sized for 3000 cfm. O There is a normally closed, motor-operated valve on the hydrogen skimmer suction line to reduce ice condenser bypass during initial blowdown. The two trains are initiated , automatically on a containment pressure high-high signal. The automatic action is to open the motor operated valve on the hydrogen skimer suction line after a 9
- 1 minute- ,
delay. Once the valve has fully opened, the hydrogen j skimmer fan will start. Each train is powered from a separate emergency power supply. Since each train fan can provide 100% of the mixing requirements, the System will provide its design function with a limiting single active failure. Air is drawn from the dead ended compartments by the mixing
~
fans and is discharged toward the upper regions of the containment. This complements the air patterns established by.the. containment air return fans, which take suction from - the. operating floor level and discharge to the . lower regions
' (continued).
(
~
l1 McGuire Unit l'. B 3.6-52 Supplement 2 f
'l
HSS B 3.6.8 BASES BACKGROUND of the containment, and the containment spray, which cools (continued) the air and causes it to drop to lower elevations. The systems work together such that potentially stagnant areas where hydrogen pockets could develop are eliminated. APPLICABLE The HSS provides the capability.for reducing the local SAFETY ANALYSES hydrogen concentration to approximately the bulk average concentration. The limiting DBA relative to hydrogen concentration is a LOCA. Hydrogen may accumulate in containment following a LOCA as a result of:
- a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant;
- b. Radiolytic decomposition of water in the Reactor Coolant System (RCS) and the containment sump;
- c. Hydrogen in the RCS at the time of the LOCA (i.e.,
hydrogen dissolved in the reactor coolant and hydrogen p gas in the pressurizer vapor space); or b d. Corrosion of metals exposed to containment spray and Emergency Core Cooling System solutions. To evaluate the potential for hydrogen accumulation in containment following a LOCA, the hydrogen generation as a function of time following the initiation of the accident is calculated. Conservative assumptions recomended by Reference 3 are used to maximize the amount of hydrogen calculated. The HSS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4). LC0 Two HSS trains must be OPERABLE, with power to each from an independent, safety related power supply. Each train consists of one fan with its own motor and controls and is automatically initiated by a containment pressure high-high signal. l l (continued) L) . McGuire Unit 1 8 3.6-53 Supplement 2 l t i
c - . HSS-B 3.6.8' BASES ~ LCO Operation with at least one HSS train provides the mixing (continued) necessary to ensure uniform hydrogen concentration throughout containment. APPLICABILITY- In MODES 1 and 2, the two HSS trains ensure the' capability to prevent localized hydrogen concentrations above the flamability. limit of 4.0 volume percent in' containment assuming a worst case single active failure. In MODE 3 or 4, both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the D83A LOCA. Also, because of the limited time in these MODES, the probability of an accident' requiring the HSS .is low. Therefore, the HSS is not required in MODE 3 or 4. In MODES 5 and 6, the probability and consequences of a LOCA
- k. or steam line break (SLB) are reduced due to the pressure and temperature ' limitations in these MODES. Therefore, the HSS is not required in these MODES.
' ACTIONS L1 With one HSS train inoperable, the inoperable train must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE HSS train is adequate to perfonn the hydrogen mixing function. However, the overall reliability is reduced because a single failure in the OPERABLE train could result in reduced hydrogen mixing capability. 0.ie 30 day Completion Time is based on the availability of the other HSS train, the small probability of a LOCA or SLB occurring (that would generate an amount of hydrogen that exceeds the flamability limit), the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit, and the availability of the hydrogen recombiners and Hydrogen Mitigation System.
Required Action A.1 has been modified by a Note that states the provisions ~of LCO 3.0.4 are not applicable. As a result, a MODE change is allowed when one HSS train is (continued) fMcGuireUnitI B 3.6-54 Supplement 2
HSS-
~8 3.6.8 BASES
~
ACTIONS- M (continued) inoperable. This. allowance is based on the availability of the other HSS train, the small probability of a LOCA or SLB occurring (that.would generate-an amount of hydrogen that exceeds the flammability limit).. and the amount of time available after a LOCA or SLB (should one occur) for operator-action to prevent hydrogen accumulation from exceeding the flammability limit. M If an inoperable HSS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a h0DE in which the LC0 does not apply. To achieve this status, .the plant must be brought to at least MODE 3.within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner 1 and without challenging plant systems. SURVEILLANCE SR 3.6.8.1 REQUIREMENTS Operating each HSS train for a 15 minutes ensures that each train is OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan and/or motor failure, or excessive vibration can be detected for corrective action. The 92 day Frequency is consistent with Inservice Testing Program Surveillance Frequencies, operating experience, the known reliability of the fan motors and controls, and the two train redundancy available. SR 3.6.8.2 Verifying HSS fan motor current at rated speed with the motor operated suction valves closed is indicative of overall fan motor performance and system flow. Such 1.9 service tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnonna) performance. The Frequency of 92 days was based on operating experience which has shown this Frequency to be acceptable. s (continued) _ -McGuire Unit 1- B 3.6-55 Supplement 2 l
HSS B 3.6.8 BASES
' SURVEILLANCE SR 3.6.8.3 . REQUIREMENTS-(continued) This SR verifies the operation of the motor operated suction valves and HSS fans in response to a start permissive from the Containment Pressure Control System (CPCS). The CPCS is described in the Bases for LC0 3.3.2, "ESFAS." The Frequency of 92 days was based on operating experience which has shown this Frequency to be acceptable.
SR 3.6.8.4 This SR ensures that each HSS train responds properly to a containment pressure high-high actuation signal. The Surveillance verifies that each fan starts after a delay of
- t 8 minutes and : 10 minutes. The Frequency of 92 days conforms with the testing requirements for similar ESF equipment and considers the known reliability of fan motors and controls and the-two train redundancy available.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. REFERENCES 1. 10 CFR 50.44.
- 2. 10 CFR 50, Appendix A, GDC 41.
- 3. Regulatory Guide 1.7, Revision 0.
- 4. 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
l: McGuire Unit 1 B 3.6-56 Supplement 2
~
HMS B 3.6.9 8 3.6 CONTAINMENT' SYSTEMS B 3.6.9 Hydrogen Mitigation System (HMS) BASES BdCKGROUND The HMS ' reduces the potential for breach of primary containment due to a hydrogen oxygen reaction.in post accident environments. The HMS is' required by 10 CFR 50.44,
" Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors" (Ref.1), and Appendix A .
GDC 41, " Containment Atmosphere Cleanup" (Ref. 2), to reduce the hydrogen concentration in the primary containment following a degraded' core accident. The HMS must be capable of handling an amount of hydrogen equivalent to that generated from a metal water reaction involving 75% of the fuel cladding surrounding the active fuel region (excluding the plenum volume). 10 CFR 50.44 (Ref.1) requires units with ice condenser containments to install . suitable hydrogen control systems that would acconinodate an amount of hydrogen equivalent to that generated from the reaction of 75% of the fuel cladding with water. The HMS provides this required capability. This requirement was placed on ice condenser units because O of their small containment volume and low design pressure (compared with pressurized water reactor dry containments). Calculations indicate that if hydrogen equivalent to that generated from the reaction of 75% of the fuel cladding with water were to collect in the primary containment, the < resulting hydrogen concentration would be far above the lower flaninability limit such that, if ignited from a random ignition source, the resulting hydrogen burn would seriously challenge the containment and safety systems in the containment.- The HMS is based on the concept of controlled ignition using thermal ignitors, designed to be capable of functioning in a-post accident environment, seismically supported, and capable of actuation from the control room. A total of - 70 ignitors are distributed throughout the various regions - of ' containment in which hydrogen could be released or to q g < (continued) g I
,McGuire Unit _1 B 3.6-57 Supplement 2 l 1
HMS B 3.6.9 1 BASES l (O) BACKGROUND which it could flow in significant quantities. The ignitors (continued) are arranged in two independent trains such that each containment region has at least two ignitors, one from each train, controlled and powered redundantly so that ignition would occur in each region even if one train failed to energize. When the HMS is initiated, the ignitor elements are energized and heat up to a surface temperature a 1700*F. At this temperature, they ignite the hydrogen gas that is present in the airspace in the vicinity of the ignitor. The HMS depends on the dispersed location of the ignitors so that local pockets of hydrogen at increased concentrations would burn before reaching a hydrogen concentration significantly higher than the lower flamability limit. Hydrogen ignition in the vicinity of the ignitors is assumed to occur when the local hydrogen concentration reaches 8.5 volumepercent(v/o)andresultsin100%ofthehydrogen present being consumed. APPLICABLE The HMS causes hydrogen in containment to burn in a p SAFETY ANALYSES controlled manner as it accumulates following a degraded d core accident (Ref. 3). Burning occurs at the lower flamability concentration, where the resulting temperatures and pressures are relatively benign. Without the system, hydrogen could build up to higher concentrations that could result in a violent reaction if ignited by a random ignition source after such a buildup. The hydrogen ignitors are not included for mitigation of a Design Basis Accident (DBA) because an amount of hydrogen equivalent to that generated from the reaction of 75% of the fuel cladding with water is far in excess of the hydrogen calculated for the limiting DBA loss of coolant accident (LOCA). The hydrogen concentration resulting from a DBA can be maintained less than the flammability limit using the hydrogen recombiners. The hydrogen ignitors, however, have been shown by probabilistic risk analysis to be a significant contributor to limiting the severity of accident sequences that are commonly found to dominate risk for units with ice condenser containments. As such, the hydrogen s , ignitors satisfy Criterion 4 of 10 CFR 50.36 (Ref. 4). i O V (continued) l: McGuire Unit 1 B 3.6-58 Supplement 2
HMS B 3.6.9 BASES (continued)~ LC0 Two'HMS trains must be OPERABLE with' power from two independent, safety related power supplies. For.this unit, an OPERABLE HMS train consists of 34 of-35 ignitors energized on the train. Operation with at least one HMS train ensures that the hydrogen in containment can be burned in a controlled - manner. Unavailability of both HMS. trains could lead to-hydrogen buildup to higher concentrations, which could result in a. violent. reaction if ignited. The reaction could take. place fast enough to lead to Mg5 temperatures and overpressurization of containment and, as a result, breach containment or cause containment leakage rates above those assumed in the safety analyses. Damage to safety related-equipment located in containment could also occur. APPLICABILITY Requiring OPERABILITY in MODES 1 and 2 for the HMS ensures its insnediate availability after safety injection and scram actuated on a LOCA initiation. In the post accident environment, the two HMS subsystems are required to control fl the hydrogen concentration within containment to near its U flaninability limit of 4.0 v/o assuming a worst case single failure. This prevents overpressurization of containment and damage to safety related equipment and instruments located within containment. In MODES 3 and 4, both the hydrogen production rate and the total hydrogen production after a LOCA would be significantly less than that calculated for the DBA LOCA. Also,- because of the limited time in these MODES, the i probability of an accident requiring the HMS is low. Therefore, the HMS is not required in MODES 3 and 4. In MODES 5 and 6, the probability and consequences of a LOCA are reduced due to the pressure and temperature limitations of these MODES. Therefore, the HMS is not required to be OPERABLE in MODES 5 and 6. i' (continued)
'McGuire Unit 1 B 3.6-59 - Supplement 2 l
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HMS. B 3.6.9 BASES - (continued)'. ACTIONS A.1 and A.2 With one HMS train inoperable, the inoperable train must be
. restored to OPERABLE status within 7 days or the' OPERABLE-train must be verified OPERABLE frequently by performance of'.
SR 3.6.9.1. The 7; day Completion Time. is based on the low- _
. probability.of the' occurrence of a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75F of the core cladding, the length of time after the event that operator action would be required to prevent hydrogen accumulation from exceeding this limit, and the low probability of failure of the OPERABLE HMS train. Alternative Required Action A.2, by frequent surveillances, provides assurance that the OPERABLE train continues to-be OPERABLE.
IL1 Condition B is one containment region with no OPERABLE hydrogen ignitor. Thus, while in Condition B, or in Conditions A and B. simultaneously there would always be
, ignition capability in the adjacent containment regions that would provide redundant capability by flame propagation to the region with no OPERABLE ignitors.
I Required Action B.1 calls for the restoration of one hydrogen ignitor in each region to OPERABLE status within 7 days. The 7 day Completion Time is based on the same reasons given under Required Action A.1. fu.1 ine unit must be placed in a MODE in which the LCO does not apply if the HMS subsystem (s) cannot be restored to OPERABLE status within the associated Completion Time. This is done by placing the unit in at least MODE 3 within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. (continued) llf McGuire Unit 1 B 3.6-60 Supplement 2
HMS B 3.6.9 fm BASES (continued) b ' SURVEILLANCE SR 3.6.9.1 REQUIREMENTS This SR confirms that a 34 of 35 hydrogen ignitors can be successfully energized in each train. The ignitors are simple resistance elements. Therefore, energizing provides assurance of OPERABILITY. The allowance of one inoperable hydrogen ignitor is acceptable because, although one inoperable hydrogen ignitor in a region would c.ampromise redundancy in that region,.the containment regions are interconnected so that ignition in one region would cause burning to progress to the others (i.e., there is overlap in each hydrogen ignitor's effectiveness between regions). The Frequency of 92 days has been shown to be acceptable through operating experience. SR 3.6.9.2 This SR confirms that the two inoperable hydrogen ignitors allowed by SR 3.6.9.1 (i.e., one in each train) are not in the same containment region. The Frequency of 92 days is acceptable based on the_ Frequency of SR 3.6.9.1, which provides the information for performing this SR. O V 3.6.9.3 SR A more detailed functional test is performed every 18 months to verify system OPERABILITY. Each glow plug is visually examined to ensure that it is clean and that the electrical circuitry is energized. All ignitors (glow plugs), including normally inaccessible ignitors, are visually checked for a glow to verify that they are energized. Additionally, the surface temperature of each glow plug is measured to be 2 1700*F to demonstrate that a temperature sufficient for ignition is achieved. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the ; SR when performed at the 18 month Frequency, which is ' based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. (continued) EMcGuire Unit 1 B 3.6-61 Supplement 2 l
HMS B 3.6.9 BASES (continued) REFERENCES 1. 10 CFR 50.44,
- 2. 10 CFR 50, Appendix A, GDC 41.
- 3. UFSAR, Section 6.2.
4.- 10 CFR 50.36, Technical Specifications (c)(2)(ii). 1 1 l l .i 4
.l McGuire' Unit ~1 .B 3.6-62 Supplement 2 l
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T' AVS B 3.6.10 B 3.6 CONTAINMENT SYSTEMS
. B 3.6.10 Annulus l Ventilation System (AVS)
BASES
' BACKGROUND: The AVSjis required by 10 CFR 50, Appendix A GDC 41,
" Containment Atmosphere Cleanup" (Ref. 1), to ensure that radioactive materials' that leak from the primary containment into the reactor building (secondary containment) following _
a Design Basis Accident (DBA) are filtered and adsorbed _
' prior to exhausting to the environment.
The containment has a secondary containment' called the reactor building,.which is a concrete structure that-surrounds the. steel primary containment vessel . Between the containment vessel and the reactor building inner wall is an annulus that collects' any containment leakage that may occur following a loss of coolant accident (LOCA) or rod ejection accident. 'This space also allows for periodic inspection of the outer surface of the steel containment vessel. The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment. Reactor building OPERABILITY is required to ensure retention of primary containment leakage and proper operation of the AVS. The AVS consists of two separate and redundant trains. Each train includes a heater, mechanical demister, a prefilter/ moisture separator, upstream and downstream high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of radioiodines, and a fan. Ductwork,valvesand/ordampers,andinstrumentationalso 1 form part of the system. The heaters and mechanical i demisters function to reduce the moisture content of the airstream to less than 70% relative humidity. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter bank. Only the upstream HEPA filter and the charcoal adsorber section are credited in the analysis. The system initiates and maintains a negative air pressure in the reactor building annulus by means of filtered exhaust (continued)
- McGui re -. Uni t . B 3.6-63 Supplement 2 _l 1
. .. AVS B 3.6.10 BASES; ,
1
. BACKGROUND. ventilation of the reactor building annulus following
- l (continued) receipt of a-Phase B isolation signal. The' system is described in Reference 2. 1 The prefilters remove large particles in the air, and the moisture separators remove entrained water droplets present,
'to prevent excessive loading of the HEPA filters and
-charcoal absorbers. Heaters'are included to reduce the . l relative humidity of the airstream. Continuous operation of I each train, for. at least 10 hours per month, with heaters i on, reduces moisture buildup on their HEPA filters ~and 1 adsorbers. ' The mechanical demisters cool the air to keep the charcoal beds from becoming too hot due to absorption of' fission product.
. The AVS reduces the radioactive content in the annulus atmosphere following a DBA. Loss of the AVS could cause site boundary doses, in the event of a DBA, to exceed the values given in the licensing basis.
' APPLICABLE The AVS design basis is established by the consequences of the limiting DBA, which is a LOCA. The accident analysis O SAFETY ANALYSES (Ref. 3) assumes that only one train of the AVS is functional due. to a single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioactive material provided by the remaining one train of this filtration system. The amount of fission products available for release from containment is determined for a LOCA.
The modeled AVS actuation in the safety analyses is based upon a worst case response time following a Phase.B isolation signal initiated at the limiting setpoint. The total response time, from exceeding the signal setpoint to attaining the negative pressure of 0.5 inch water gauge in the reactor. building annulus, is 22 seconds. The pressure then goes to -3.5 inches water within 48 seconds after the
. start signal is initiated. At this point the system switches into its recirculation mode of operation and j
. pressure may, increase to -0.5 inches water within 278 4 tseconds but will not go above -0.5 inches water. This
- response time is composed of signal delay, diesel generator
'(continued)
W) h ~ B 3.6-64 ll McGuir.e Unit -1; Supplement 2 I e . o , , ,,r-- ,
AVS'
- B 3.6.10 BASES BACKGROUND startup and sequencing time ' system startup time, and (continued) time for the system to attain the required pressure after starting.
The AVS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4).
-LCO ..
In.the event of a DBA . one AVS train is required to provide the minimum particulate iodine removal. assumed in the safetyL. analysis. -Two. trains of the AVS must be OPERABLE to ensure that at_least one train will operate, assuming that the
; other train is disabled by a single active failure.
APPLICABILITY In MODES '1, 2, 3, and 4, a DBA could lead to fission product release to containment that leaks to the reactor building. The large break LOCA, on which this system's design is based, is a full power event. Less severe LOCAs and leakage still require the system to be OPERABLE throughout these MODES. The probability and severity of a LOCA decrease as core power and Reactor Coolant System pressure decrease. With the reactor shut down, the probability of release of O radioactivity resulting from such an accident is low. In MODES 5 and 6, the probability and consequences of a DBA are low due to the pressure and temperature limitations in these MODES. . Under these conditions, the AVS is not required to be OPERABLE. 1 ACTIONS Ad With one AVS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant AVS train and the low probability of a DBA occurring during this period. -The Completion Time is adequate to make most. repairs. (continued) . :D , a b
?_ _l LMcGuire Unit-1 B 3.6-651 Supplement 2 'l 1 .
AVS B 3.6.10 =p. . BASES V ACTIONS' B.1 and 8.2 (continued) With one or more AVS heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated within.7 days in accordance with Specification 5.6.6, which details the reason for.the-heater's inoperability and' the corrective action required to return the heater to OPERABLE status. The heaters do not affect OPERABILITY of the AVS filter train because charcoal adsorber efficiency testing is performed at.30*C and 95% relative humidity. The accident analysis shows that site boundary-radiation doses are within 10 CFR 100 limits during a DBA LOCA under these- conditions. C.1 and C.2 If the AVS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The O allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.10.1 REQUIREMENTS Operating each AVS train from the control room with flow through the HEPA filters and activated carbon adsorbers ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on for 2 10 continuous hours eliminates moisture on the adsorbers and HEPA filters. Experience from filter testing at. operating units indicates that the 10 hour period is adequate for moisture elimination on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and l (continued) l ' McGui re Unit 1.' B 3.6-66 Supplement 2
AVS B 3.6.10 p BASES ( SURVEILLANCE SR 3.6.10.1 (continued) REQUIREMENTS controls, the two train redundancy available, and the iodine removal capability of the Containment Spray System and Ice Condenser. SR 3.6.10.2 This SR verifies that the required AVS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The AVS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 5) with exceptions as noted in the UFSAR. The VFTP includes testing HEPA filter ' performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and followir.g specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP. SR 3.6.10.3 N The automatic startup on a Containment Phase B Isolation -(d signal ensures that each AVS train responds properly. The 18 month Frequency is based on the need to perform this 4 Surveillance under the conditions that apply during a plant i outage and the potential for an unplanned transient if the i Surveillance were performed with the reactor at power. I Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. Furthermore, the SR interval was developed considering that the AVS equipment OPERABILITY is demonstrated at a 31 day Frequency by , I SR 3.6.10.1. SR 3.6.10.4 The AVS filter cooling electric motor-operated bypass valves are tested to verify 0PERABILITY. The valves are normally closed and may need to be opened to initiate miniflow cooling through a filter unit that has been shutdown following a DBA LOCA. Miniflow cooling may be necessary to limit temperature increase in the idle filter train due to l 7 (continued) j A. ; McGuire Unit 1 B 3.6-67 Supplement 2 l
l AVS B 3.6.10 BASES: SURVEILLANCE SR 3.6.10.4 (continued) REQUIREMENTS' decay heat from captured fission products. The 18 month Frequency is considered to be acceptable based on valve reliability and design, and the fact'that operating
- experience has shown.that.the valves usually pass the Surveillance when perfonned at the 18 month Frequency. .
SR 3.6.10.5 The proper functioning of the fans. dampers, filters, adsorbers, etc., as a system is verified by the ability of
.each train to produce the required system flow rate. The 18 month Frequency is consistent with Regulatory Guide 1.52 (Ref.-5) guidance for functional testing.
REFERENCES 1. 10 CFR 50, Appendix A, GDC 41..
- 2. UFSAR, Section 6.2.
- 3. UFSAR, Chapter 15.
- 4. 10 CFR 50.36, Technical Specifications, (c)(2)(11).
- 5. Regulatory Guide 1.52, Revision 2.
I l l
, l;McGuire. Unit 1- B 3.6-68 Supplement 2-
- 3
ARS B 3.6.11 .q B 3.6 CONTAINMENT SYSTEMS B 3.6.11 Air Return System (ARS) BASES BACKGROUND The ARS is designed to assure the rapid return of air from the upper to the lower containment compartment after the initial blowdown following a Design Basis Accident (DBA). The return of this air to the lower compartment and subsequent recirculation back up through the ice condenser assists in cooling the containment atmosphere and limiting post accident pressure and temperature in containment to less than design values. Limiting pressure and temperature reduces the release of fission product radioactivity from containment to the environment in the event of a DBA. The ARS also promotes hydrogen dilution by mixing the hydrogen with containment atmosphere and distributing throughout the containment. The ARS consists of two separate trains of equal capacity, each capable of meeting the design bases. Each train includes a 100% capacity air return fan and associated motor operated damper in the fan discharge line to the containment
/7 lower compartment. The damper acts as a barrier between the V upper and lower compartments to prevent reverse flow which would bypass the ice condenser. The damper is normally closed and remains closed throughout the initial blowdown following a postulated high energy line break. The damper motor is actuated several seconds after the containment pressure high-high setpoint is reached and a start permissive from the Containment Pressure Control System is present. A backdraft damper is also provided at the discharge of each fan to serve as a check damper on the non-operating train. Each train is Engineered Safety Features (ESF) bus. powered from a separate The ARS fans are automatically started by the containment pressure high-high signal 9
- 1 minutes after the containment pressure reaches the pressure setpoint and a start permissive from the Containment Pressure Control System is present. The time delay ensures that no energy released during the initial phase of a DBA will bypass the <
ice bed through the ARS fans. '
- n (continued)
- Q
'McGuire Unit 1 8 3.6-69 Supplement 2 l
_ _ ____--___________ __ _ -----____u
'ARS B 3.6.11
. BASES i
BACKGROUND After starting, the fans displace-air from the upper (continued) compartment to the lower compartment,.thereby returning the air that was displaced by the high energy line break blowdown from the lower compartment and equalizing pressures i throughout containment._ After discharge into the lower compartment, air flows with steam produced by' residual heat through the ice condenser doors into the ice condenser compartment where the steam portion of the flow is condensed. The air flow returns to the upper compartment through the top deck doors in the upper portion of the ice .! condenser compartment. The ARS fans operate continuously after actuation, circulating air through the containment volume. When the containment pressure falls below a predetermined value, the ARS fans are automatically de-energized. Thereafter, the fans are automatically cycled on and off if necessary to control any additional containment pressure transients. The ARS also functions, after all the ice has melted, to circulate any steam still entering the lower compartment to the upper compartment where the Containment Spray System can cool it. O V The ARS is an ESF system. It is designed to ensure that the heat removal capability required during the post accident period can be attained. The operation of the ARS, in conjunction with the ice bed, the Containment Spray System, and the Residual Heat Removal (RHR) System spray, provides the required heat removal capability to limit post accident conditions to less than the containment design values. 1 APPLICABLE The limiting DBAs considered relative to containment
-SAFETY ANALYSES temperature and pressure are the loss of coolant accident (LOCA) and the steam line break (SLB). The LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients.
DBAs are assumed not to occur simultaneously or consecutively. The postulated DBAs are analyzed. in regard l to ESF systems, assuming the loss of one ESF bus, which is ! the worst case single active failure and results in one train each of the Containment Spray System, RHR System, and l
.ARS being inoperable (Ref.1). The DBA analyses show that~ l the. maximum peak containment pressure results from the LOCA j I
ys (continued)
-[McGuireUnit1.. B 3.6-70 Supplement 2 l 2
1 ARS B 3.6.11
. BASES ,
.APPLICABLEL analysis and is calculated to be less than the containment SAFETY ANALYSES design pressure. i (continued)
For certain aspects.of transient accident analyses, maximizing the calculated containment pressure is not conservative. . In particular, the cooling effectiveness of - the Emergency' Core Cooling System during the core reflood ' phase of a LOCA analysis increases with increasing I" containment-backpressure. For these calculations, the containment backpressure is calculated in a manner designed to conservatively minimize, rather than. maximize, the calculated transient containment pressures, in accordance with 10 CFR 50,_ Appendix K (Ref. 2). ] The analysis for minimum internal containment pressure
-(i.e., maximum external differential containment pressure) ,
assumes inadvertent simultaneous actuation of both the ARS- J and the Containment Spray System. 1 Ii The modeled ARS actuation from the containment analysis is based upon a response time associated with exceeding the containment pressure High-High signal setpoint to achieving full ARS air flow. A delayed' response time initiation d provides conservative analyses of peak. calculated . O containment temperature and pressure responses. The ARS total response time of 600 seconds includes signal delays. J The ARS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 3). LC0 In the event of a DBA, one train of the ARS is required to a provide the minimum air recirculation for heat removal assumed in the safety analyses. To ensure this requirement is met, two trains of the ARS must be OPERABLE. This will ensure that at least one train will operate, assuming the 4 worst case single failure occurs, which is in the ESF power
. supply.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature requiring the operation of the ARS. Therefore, the LCO is applicable in MODES 1, 2, 3, and 4. (continued) { gr '
?
McGuire. Unit 1 B 3.6-71 Supplement 2 l l j
.m
ARS B 3.6.11 BASES b APPLICABILITY In MODES 5 and 6, the probability and consequences of these (continued) events.are reduced due to the pressure and temperature limitations of these MODES. Therefore, the ARS is not required to be OPERABLE inlthese MODES. ACTIONS- Ad
~
If one of the required trains of the ARS is inoperable, it must be restored to OPERABLE status within 72 hours. The. 72 hour Completion Time was developed taking into account the redundant flow of the OPERABLE- ARS train and the low. probability of a DBA occurring -in this period. B.1 and B.2 If the ARS train cannot be restored to OPERABLE status within- the required Completion Time, .the plant must be brought to a MODE'in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The /* allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an. orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.11.1 REQUIREMENTS Verifying that each ARS fan starts on an actual or simulated actuation signal, after a delay 2 8.0 minutes and s 10.0 minutes, and operates for 215 minutes is sufficient to ensure that all fans are OPERABLE and that all associated controls and time delays are functioning properly. It also ensures that blockage, fan and/or motor failure, or excessive vibration can be detected for-corrective action.
-The 92 day Frequency was developed considering the known reliability of fan motors and controls = and the two train-redundancy available.
'(continued) lfMcGuire Unit IE B 3.6-72 Supplement 2
.ARS B 3.6.11- .rN t
BASES SURVEILLANCE' SR 3.'6.11.2 REQUIREMENTS. . (continued) . Verifying ARS fan motor current to be at rated speed with the return air dampers closed confirms one operating condition of the fan. This test is indicative of overall fan motor. performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient. failures by indicating abnormal performance. The Frequency of 92 days conforms with the testing requirements for similar ESF equipment and considers the known reliability of fan motors and controls and the two train redundancy available. 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 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 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 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, their location, physical environment, and probability-of failure. Operating experience has also shown this Frequency to be acceptable. SR 3.6.11.6 and SR 3.6.11.7 These SRs . require verification that each ARS motor operated damper opens or is prevented from opening and each ARS fan-is allowed to start or is prevented from starting upon receipt of. Containment Pressure Control System start
. permissive ~ and. terminate signals. The CPCS is described -in m (continued)
D
- c. ; McGuire Unit 1 B 3.6'-73 Supplement 2 [
n,
1 ARS B 3.6.11 BASES O- 4 SURVEILLANCE SR 3.6.11.6 and SR 3.6.11.7 (continued) REQUIREMENTS the Bases for 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.
- 2. 10 CFR 50, Appendix K.
- 3. 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
O i 1
- D
%f l : McGuire Unit 1 B 3.6-74~ Supplement 2
Ice bid l
.B-3.6.12 l i
'8'3.6 CONTAINMENT' SYSTEM'S O B 3.6.12 . Ice Bed BASES
-BACKGROUND The ice bed consists of over 2,099,790 lb of ice stored in 1944 baskets within the. ice condenser. . Its primary purpose
! is to . provide a large heat ' sink in the event of a release of energy from a Design Basis Accident (DBA) in containment. The ice would absorb energy. and limit containment peak pressure and temperature during the accident transient. Limiting the pressure and temperature reduces the release ofL fission product radioactivity from containment to the environment in the event of a DBA. The ice. condenser is an annular compartment . enclosing approximately 300' of the perimeter of the upper containment compartment, but penetrating the operating deck so that a portion extends into the lower containment compartment. The lower portion has a series of hinged doors exposed to the atmosphere of the lower containment compartment, which, for normal unit operation, are designed to remain closed. At the top of the ice condenser is another set of doors exposed
- l. to the atmosphere of the upper compartment, which also remain closed during nonnal unit operation. Intermediate.
i deck doors, located below the top deck doors, fonn the floor l' of a plenum at the upper part of the ice condenser. These doors also remain closed during nonnal unit operation. The upper plenum area is used to facilitate surveillance and maintenance of the ice bed. l: The ice baskets held in the ice bed within the ice condenser 3 , are arranged to promote heat transfer from steam to ice. l This arrangement enhances the ice condenser's primary j- function of condensing steam and absorbing heat energy released to the containment during a DBA. In the event of a DBA, the ice condenser inlet doors (located below the operating deck) open due to the pressure rise in the lower compartment. This allows air and steam to flow from the lower compartment into the ice condenser. The (continued)
- h. '
JMcGuire Unit 1- Supplement 2- l. B.3.6-75 s
Ice Bad B 3.6.12 BASES BACKGROUND- resulting pressure increase within the ice condenser causes (continued)_ the intermediate deck doors and the top deck doors to open, i which allows the air to flow out of the. ice condenser into l the upper compartment. Steam condensation within the ice , condenser limits the pressure and temperature buildup.in ! containment. A divider barrier separates the upper and i Iower compartments and ensures that the steam is directed
- - into the ice condenser.
-l The ice, together with the containment spray, is adequate to- !
, absorb the initial blowdown of steam and water from a DBA - J l and the additional . heat loads that would enter containment ! ! during several hours following the initial. blowdown. The' i additional heat loads would come from the residual heat in ! the reactor core, the hot piping and components, and the secondary system, including the steam generators. During the post blowdown. period, the Air Return System (ARS) returns upper compartment air through the divider barrier to the lower compartment. This serves to equalize pressures in containment and to continue circulating heated air and steam from the lower compartment through the ice condenser where the heat is removed by the remaining ice. i As ice melts, the water passes through the ice condenser Ls floor drains into the lower compartment. Thus, a second function of the ice bed is to be a'large source of borated water (via the containment sump) for long term Emergency Core Cooling System (ECCS) and Containment Spray System heat L removal functions in the recirculation mode. A third function of the ice bed and melted ice is to remove fission product iodine that may be released from the core during a DBA. Iodine removal occurs during the ice melt phase of the accident and continues as the melted ice is sprayed into the containment atmosphere by the Containment Spray System. .The ice is adjusted to an alkaline pH that facilitates removal of radioactive iodine from the containment atmosphere. The alkaline pH also minimizes the occurrence of the chloride and caustic stress corrosion on mechanical systems and components exposed to ECCS and
- Containment Spray System fluids in the recirculation mode of operation.
It is important for_ the ice to be uniformly distributed around the 24 ice. condenser bays and for open flow paths to exist around ice baskets. This~is especially important-(continued) t McGuire Unit l' B 3.6-76 Supplement 2-Et E
Ice Bed
.B 3.6.12 BASES-
- 4' BACKGROUND during the initial blowdown so that the steam and water (continued) mixture entering the lower compartment do not pass through only part of the ice condenser, depleting the ice there while bypassing the ice in other bays.
Two phenomena that can degrade the ice bed during the long-service period are:
- a. Loss of ice by melting or sublimation; and
- b. Obstruction of flow passages through the ice bed due to buildup of frost or ice._ Both of these degrading phenomena are reduced by minimizing air leakage into and out of the ice condenser.
The ice bed limits the temperature and pressure that could i be expected following a DBA, thus limiting leakape of fission product radioactivity from containment to the environment. i APPLICABLE The limiting DBAs considered relative to containment temperature and pressure are the loss of coolant accident O SAFETY ANALYSES (LOCA) and the steam line break (SLB). The LOCA and SLB are analyzed using computer codes designed to predict the j resultant containment pressure and temperature transients. ! DBAs are not assumed to occur simultaneously or
~
consecutively. Although the ice condenser is a passive system that requires no electrical power to perform its function, the Containment Spray System, RHR Spray System, and the ARS also function to assist the ice bed in limiting pressures and temperatures. Therefore, the postulated DBAs are analyzed in regards to containment Engineered Safety Feature (ESF) systems, i assuming the loss of one ESF bus, which is the worst case ! single active failure and results in one train each of the 1 Containment Spray System, RHR Spray System, and ARS being inoperable. The limiting DBA analyses (Ref. 1) show that the maximum j peak containment pressure results from the LOCA analysis and l 1s calculated to be less than the containment design
. pressure. For certain aspects of the transient accident:
( (continued) 1
- McGuire Unit 1 B 3.6-77 Supplement 2 l
c j Ice B:d~ i B 3.6.12 I BASES-
' APPLICABLE: analyses, maximizing-the calculated containment pressure is SAFETY ANALYSES not conservative. In particular, the' cooling effectiveness
-(continued) of the ECCS during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For
! these calculations, the containment backpressure is calculated in a manner designed to conservatively minimize, rather. than maximize, the calculated transient containment pressures, in accordance with.10 CFR 50, Appendix K (Ref.2). The maximum peak containment atmosphere temperature results from the SLB analysis and is discussed in the Bases for LCO 3.6.5, " Containment Air Temperature." In addition to calculating the overall peak containment-L pressures, the DBA analyses include calculation of the l transient differential pressures that occur across
- subcompartment walls during the initial blowdown phase of the. accident transient. The internal containment walls and structures are designed to withstand.these local transient pressure differentials for the limiting DBAs.
The ice bed satisfies Criterion 3-of 10 CFR 50.36 (Ref. 3); I f LC0 The ice bed LC0 requires the existence of the required quantity of stored ice, appropriate distribution of the ice L and the ice bed, open flow paths through the ice bed, and appropriate chemical content and pH of the stored ice. The ! stored ice functions to absorb heat during a DBA, thereby limiting containment air temperature and pressure. The 1 chemical content and pH of the ice provide core SDM (boron content) and remove radioactive iodine from the containment l atmosphere when the melted ice is recirculated through the J ECCS and the Containment Spray System, respectively. I J
-APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature requiring the operation ,
of the ice bed. Therefore, the LCO is applicable in MODES 1. 2 -3, and 4. W, (continued) Q 4 l McGuire Unit 1 B 3.6-78' Supplement 2
m t
~ Ice Bed 7 .
B 3.6.12
' BASES l -q.
APPLICABILITY ~ InMODES5and'6,theprobabilityandlconsequencesofthese (continued) events are reduced due to the pressure and temperature limitations of>these MODES. Therefore, the ice _ bed is not: ' required to be OPERABLE in these MODES. L L ACTIONS Ad If the ice bed is inoperable, it must be restored to '! OPERABLE status within 48 hours. The Completion Time was developed based on operating experience, which confirms that due. to the very large mass of stored ice, the parameters comprising OPERABILITY do not change appreciably in this time period. Because'of this fact, the Surveillance ,- Frequencies are long (months), except for the ice bed temperature, which is checked every 12 hours.- If a degraded i condition is identified, even for temperature, with such a' ! large mass of ice it is not possible for the degraded ;
, condition to significantly degrade further in a 48 hour- )
! period. Therefore, 48 hours is a reasonable amount of time ! u to correct a degraded condition before initiating a ! shutdown. lO L ! B.1 and B.2 ; l I If the ice bed cannot be restored to OPERABLE status within j- the required Completion Time, the plant must be brought to a H0DE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating ! experience, to reach the required plant conditions from full L power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE- ~ 'SR 3.6.12.1 REQUIREMENTS Verifying that the maximum temperature of the ice bed is s 27'F ensures that the ice is kept well below toe melting point. The'12 hour Frequency was based on operating experience, which confirmed that, due to the large mass of stored. ice, it is not possible for the ice bed temperature ,
; $ (continued). '0 -
McGuire Unit 1- i8 3.6-79 Supplement 2 l w p,
,s 1
Ica B:d-B 3.6.12 m BASES V 1
' SURVEILLANCE SR 3.6.12.1 (continued) 1 REQUIREMENTS to degrade significantly within a 12 hour period and was also based on assessing the proximity of the LCO limit to the melting temperature.
Furthermore, the 12 hour Frequency is considered adequate in view of indications in the control room, including the alarm, to alert the operator to an abnormal ice bed 1 temperature condition. This SR may be satisfied by use of the Ice Bed Temperature Monitoring System. j 1 SR 3.6.12.2 i The weighing program is designed to obtain a representative sample of the ice baskets. The representative sample shall include 6 baskets from each of the 24 ice condenser bays and shall consist of one basket from radial rows 1, 2, 4, 6, 8, and 9. If no basket from a designated row can be obtained for weighing, a basket from the same row of an adjacent bay shall be weighed. O The rows chosen include the rows nearest the inside and outside walls of the ice condenser (rows 1 and 2, and 8 j U and 9, respectively), where heat transfer into the ice condenser is most likely to influence melting or sublimation. Verifying the total weight of ice ensures that there is adequate ice to absorb the required amount of energy to mitigate the DBAs. If a basket is found to contain < 1081 lb of ice, a representative sample of 20 additional baskets from the same bay shall be weighed. The average weight of ice in these 21 baskets (the discrepant basket and the 20 additional baskets) shall be :t 1081 lb at a 95% confidence level. Weighing 20 additional baskets from the same bay in the event a Surveillance reveals that a single basket contains
< 1081 lb ensures that no local zorie exists that is grossly deficient in ice. Such a zone could experience early melt out during a DBA transient, creating a path for steam to pass through the ice bed without being condensed. The Frequency of 9 months was based on ice storage tests and the allowance built into the required ice mass over and above (continued) v.
l McGuire Unit 1- B 3.6-80 Supplement 2 L
IceBid B 3.6.12 f BASES . ( SURVEILLANCE- sR- 3.6.12.2 (continued). REQUIREMENTS-the mass' assumed in the safety analyses. Operating experience has verified that, with the 9 month Frequency, the weight requirements are maintained with no significant degradation between surveillances. SR '3.6.12.3 This SR ensures that the azimuthal distribution of ice is reasonably unifonn, by verifying that the average ice weight in each of three azimuthal groups of ice condenser bays is within the limit. The Frequency of 9 months was based on ice storage tests and the allowance built into the required ice mass over and above the mass assumed in the safety analyses. Operating experience has verified that, with the 9 month Frequency, the weight requirements are maintained with no significant degradation between surveillances. SR 3.6.12.4 This SR ensures that the flow channels through the ice O condenser have not accumulated an excessive amount of ice or frost blockage. The visual inspection must be made for two or more flow channels per ice condenser bay and must include the following specific locations along the flow channel:
- a. Past the lower inlet plenum support structures and turning vanes;
- b. Between ice baskets;
- c. Past lattice frames;
- d. Through the intermediate floor grating; and
. e. Through the top deck floor grating.
The allowable 0.38 inch thick buildup of frost or ice is based on the analysis of containment response to a DSA with partial blockage of the' ice condenser flow passages, If a flow channel in a given bay is found to have an accumulation (continued) lMcGuire UnitL I. B 3.6-81. Supplement 2 ' l i.___
~ ~ Ic'e Bsd B 3.6.12 BASES lO t'
SURVEILLANCE 58.-3.6.12.4 (continued) REQUIREMENTS-of frost or ice > 0.38 inch thick, a representative. sample of 20 additional flow channels from the same bay must be visually inspected. If these additional flow channels are all found to be acceptable, the discrepant flow channel may be considered single, unique,.and acceptable deficiency. More than one discrepant flow channel in-a bay is not acceptable, however. These requirements are based on the sensitivity of the partial blockage analysis to additional blockage. The Frequency of 9 months was based on ice storage tests and the allowance built into the required ice mass over and above the mass assumed in the safety analyses. SR 3.6.12.5 Verifying the chemical composition of the stored ice ensures that the stored ice has a boron concentration of at least 1800 ppm as sodium tetraborate and a high pH, 2 9.0 and'
- l. t 9.5 at 20*C, in order to meet the. requirement for borated O water when.the melted ice is used in the ECCS recirculation V mode of operation. Sodium tetraborate has been proven ,
effective in maintaining the boron ' content for long storage periods, and it also enhances the ability of the solution to remove and retain fission product iodine. The high pH is required to enha.nce the effectiveness of the ice and the melted ice in removing iodine from the containment atmosphere. This pH range also minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to ECCS and Containment Spray System fluids in the recirculation mode of operation. The Frequency of 18 months was developed considering these facts:
- a. Long term ice storage tests have determined that the chemical composition of the stored ice is extremely stable;
- b. Operating experience has demonstrated that raeeting the boron concentration and pH requirements has never been a problem;'and jg[ (continued) dj K NcGuire Unit-1, B 3.6 Supplement 2 1 l
o m
, 3 j b i _ ;
Ice B d
'B 3.6.12-JBASES SURVEILLANCE SR 3.6.12.5 (continued) r- REQUIREMENTS'
,1 c. Someone would have to enter the containment to take
..' the sample, and, if the unit is at power, that person would receive a radiation dose.
SR 3.6.12.6 This SR ensures that a representative sampling of accessible portions of ice baskets, which are relatively thin walled, perforated cylinders, have not been degraded by wear, cracks,. corrosion, or other damage. Each ice basket must be raised at least 12-feet for this inspection.. The Frequency of 40 months for a visual inspection of the structural soundness of the ice baskets is based on engineering judgment and considers such factors as the thickness of the basket walls relative to corrosion rates expected in their service environment and the results of the long term ice storage testing. LREFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50, Appendix K.
- 3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
A- -[L[,
'McGuire Unit 1- B 3.6-83' Supplement 2. 'l r
A
- )
' Ice-Condensar Doors
- B 3.6.13 8 3.6~ CONTAINMENT SYSTEMS O
B 3.6.13 > Ice Condenser. Doors BASES BACKGROUND 'The ice condenser doors consist of the inlet. doors, the intermediate deck doors, and the top deck doors. The functions of the doors are to:
- a. Seal the ice condenser from air leakage during the lifetine of the unit; and
- b. Open in the event of a Design Basis Accident (DBA) to direct the-hot steam-air mixture from the DBA into the ice bed, where the ice would absorb energy and limit containment peak pressure and temperature during the accident transient.
Limiting the pressure and temperature following a DBA reduces the release of fission product radioactivity from containment to the environment. The ice condenser is an annular compartment enclosing
; approximately 300* of the perimeter of the upper containnent compartment, but penetrating the operating deck so that a portion extends 'into the lower containment compartment. The-inlet doors separate the atmosphere of the lower compartment from the ice bed inside the ice condenser. The top deck doors are above the ice bed and exposed to the atmosphere of the upper compartment. The intermediate deck doors, located below the top deck doors, form ~ the floor of a plenum at the upper part of the ice condenser. This plenum area'is used to facilitate surveillance and naintenance of the ice bed.
The ice baskets held:in the ice bed within the ice condenser are arranged to promote heat transfer from steam to ice. This arrangement. enhances the ice condenser's primary
. function of condensing steam and absorbing heat energy released toLthe containment during a DBA.
-(continued) 7/-~(
Lf ,[
~
l .McGuire Unit! 1 .B 3.6 Supplement l2 r b W-
I Ice Ccndenser Doors' B 3,6.13 1
,p BASES U
BACKGROOND In.the event of a DBA, the ice condenser inlet doors
'(continued) (located below the operating deck) open due to the pressure rise in the lower compartment. This: allows air and steam to-flow from the lower compartment into the ice condenser. The 1
. resulting pressure increase within the ice condenser causes '
the intermediate deck-doors and the top deck doors to open,. which allows the air to flow out of the ice condenser into the upper compartment. Steam condensation within the ice . condensers limits the pressure and ivverature buildup in containment. A divider barrier separates the upper and lower compartments and ensures that the steam is directed
'into the ice condenser.
The ice, together with the containment spray, serves as a: containment heat removal system and is acequate to absorb the initial blowdown of steam and water from a DBA as well as the additional heat loads that would enter containment during the several hours following the initial blowdown. The additional heat loads would come from the residual heat in the reactor core, the hot piping and components, and the secondary system, including the steam generators. During the post blowdown period, the Air Return System (ARS) returns upper compartment air through the divider barrier to OV the lower compartment. This serves to equalize pressures in' containment and to continue circulating heated hir and steam from the lower compartment through'the ice condenser, where the heat is removed by the remaining ice. The water from the melted ice drains into the lower compartment where it serves as a source of borated water (via the containment sump) for the Emergency Core Cooling System (ECCS) and the Containment Spray System heat removal functions in the recirculation mode. The ice (via the Containment Spray System) and the recirculated ice melt also serve to clean up the containment atmosphere. The ice condenser doors ensure that the ice stored in the ice bed is preserved during normal operation (doors closed) and that the ice condenser functions as designed if called upon to act as a passive heat sink following a DBA. (continued)
!McGuire_ Unit 1 B 3.6-85. Supplement 2 l
'? ,
~
n
^l i
' l Ice Cond:nssr Doors-n B 3.6.13 i
! BASES (continued)- l
' APPLICABLE - - The limiting DBAs considered relative to containment' SAFETY ANALYSES pressure:and temperature are the' loss of coolant accident (LOCA) and-the steam.line break (SLB). The LOCA and SLB~are
- analyzed using computer codes designed to predict the.
resultant containment pressure and temperature transients.- DBAs are assumed not to occur simultaneously or-consecutively. Although the ice condenser is'a passive system that' requires no electrical- power to perform its function, the Containment _ Spray System and ARS also function to assist the ice bed in limiting pressures and temperatures. Therefore, the postulated DBAs are analyzed with respect to Engineered Safety Feature (ESF) systems, assuming the loss of one ESF bus, which is the worst case single active failure and results in one train each of the Containment Spray System and the ARS being rendered inoperable. The limiting DBA analyses (Ref. 1) show that the maximum peak containment pressure results from the LOCA analysis and is calculated to be less than the containment design pressure. For certain aspects of transient accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the cooling ~ effectiveness , O of the ECCS during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For these calculations, the containment backpressure is calculated in a manner designed to conservatively minimize, rather than maximize, the calculated transient containment pressures, in accordance with 10 CFR 50, Appendix K (Ref.2). The maximum peak containment atmosphere temperature results from the SLB analysis and is discussed in the Bases for L LCO 3.6.5, " Containment Air Temperature." An additional' design requirement was imposed on the ice condenser door design for a small break accident in which the' flow of heated air and steam'is not sufficient to fully open the doors.- 4
' For this situation, the doors are designed so that all of )
' the doors would partially open by approximately the same amount. - Thus, the partially opened doors would modulate the ,
flow so that'each ice bay would recei re an approximately
- equal fraction _of the total flow. - {
(continued)-
- l McGuire Unit 1 - B 3.6-86 Supp1(ment 2
+
y . - - - - . inr - i . . __ _ _ , _ _ . .
Ice Ccndenser Do:rs B 3.6.13 BASES' L) APPLICABLE This design feature ensures that the heated air and steam SAFETY ANALYSES will not flow preferentially to some ice bays and deplete (continued) the ice there without utilizing the ice in the other bays. In addition to calculating the overall peak containment pressures, the DBA analyses include the calculation of the transient differential pressures that would occur across subcompartment walls during the initial blowdown phase of the accident transient. The internal containment walls and structures are designed to withs had the local transient pressure differentials for the limiting DBAs. The ice condenser doors satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3). LC0 This LC0 establishes the minimum equipment requirements to assure that the ice condenser doors perform their safety function. The ice condenser inlet doors, intermediate deck doors, and top deck doors must be closed to minimize air leakage into and out of the ice condenser, with its attendant leakage of heat into the ice condenser and loss of f ice through melting and sublimation. The doors must be ( OPERABLE to ensure the proper opening of the ice condenser in the event of a DBA. OPERABILITY includes being free of any obstructions that would limit their opening, and for the inlet doors, being adjusted such that the opening and closing torques are within limits. The ice condenser doors function with the ice condenser to limit the pressure and temperature that could be expected following a DBA. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containunt pressure and temperature requiring the operation of the ice condenser doors. Therefore, the LCO is applicable in MODES 1, 2, 3, and 4. The probability and consequences of these events in MODES 5 and 6 are reduced due to the pressure and temperature limitations of these MODES. Therefore, the ice condenser doors are not required to be OPERABLE in these MODES. (continued) McGuire Unit 1 B 3.6-87 Supplement 2 l /
Ice Condensar Do:rs B"3.6.13 y : BASES (continued)' b 3CTIONS: A Note provides clarification that.- for this LCO, separate
. Condition entry is allowed for each ice condenser ' door.
Al l If one or more ice condenser doors are inoperable due to
-being physically restrained from opening, the door (s) must be restored to OPERABLE status within 1 hour. The Required
' Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1, " Containment,"
'which requires containment to be restored to OPERABLE status within 1 hour.
B.1 and B.2 If one or more ice condenser doors are determined to be partially open or otherwise inoperable 'for reasons other than Condition A or if a door is found that is not closed, it is acceptable to continue unit operation for.up.to 14 days, provided the ice bed temperature instrumentation is monitored once per 4 hours to ensure that the open 'or s inoperable door is not allowing enough air. leakage to cause the maximum ice bed temperature to approach the melting point. The Frequency of 4 hours is based on the fact that temperature _ changes cannot occur rapidly in the ice bed-because of the large mass of ice involved. The 14 day Completion Time is based on long term ice storage tests that indicate that if the temperature is maintained below 27"F, there would not be a significant loss' of ice from sublimation. If the maximum-ice bed temperature is > 27*F at any time or if the doors are not closed and restored to OPERABLE status within 14 days, the situation reverts to Condition C and a Completion Time of 48 hours is allowed to restore the inoperable door to OPERABLE status or enter into Required Actions D.1 and D.2. Ice bed temperature must be
, verified within the specified Frequency as augmented by the provisions of SR 3.0.2. ',
(continued) (
-.J l} McGuire' Unit"1 B 3.6-88 Supplement 2 m
g.
.,. Ice Ccndensar Ddors 46 B 3.6.13 BASES:
ACTIONS- M (continued) If Required Actions B.1 or B.2-are not met, the doors must
~
be restored to OPERABLE status and closed positions within-48 hours. The 48 hour Completion Time is based on the fact that,' with the very large mass of ice involved, it would not be possible.for the temperature to increase to the melting point and a significant amount of ice to melt in a 48 hour peri od. . D.1 and D.2 If the ice condenser doors cannot be restored to OPERABLE' status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. .To achieve this status, the plant must be brought to at least MODE 3 within.6 hours and to MODE 5 within 36 hours.. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. O SURVEILLANCE SR 3.6.13.1 REQUIREMENTS Verifying, by means of the Inlet Door Position Monitoring System, that the inlet doors are in their closed positions makes the operator aware of an inadvertent opening of one or more doors. . The Frequency of 12 hours ensures that operators on each shift are aware of the status of the doors. SR 3.6.13.2
- Verifying, by visual inspection, that each intermediate deck door is closed and not impaired by ice, frost, or debris provides assurance that the intermediate deck doors (which form the floor of the. upper plenum where frequent.
- maintenance on the ice bed is performed) have not been left open or obstructed. In determining if a door is impaired by ice, the frost accumulation on the rioors, joints, and hinges
='
are to be considered in conjunction with the lifting force limits of SR 3.6.13.7. The Frequency of 7 days is based on
.., (continudd) d '
I McGuire Unit-l; B 3.6-89 Supplement 2 l
~
Y f
L Ice Condenser Dsors L 8 3.6.13 BASES < SURVEILLANCE; 38_3.6.13.2-(continued) REQUIREMENTS engineering judgment and takes into consideration such -
-factors as the frequency of entry into the intennediate ice.
condenser deck, the time required for significant frost' buildup, and the probability that a DBA will occur. SR 3.6.13.3 Verifying, by visual inspection, that the top deck doors are-in place and not obstructed provides. assurance that the. doors are performing their function of keeping warm air out of the ice condenser during normal operation, and would not be obstructed if called upon to open in response to a DBA'.. The Frequency of 92 days is based on engineering judgment, which considered such factors as the following:
- a. The relative inaccessibility and lack of traffic in the vicinity of the doors make it unlikely that a door would be inadvertently left open;
- b. Excessive air leakage would be detected by temperature monitoring in the ice condenser; and
- c. The light construction of the doors would ensure that, in the event of a DBA, air and gases passing through the ice condenser would find a flow path, even if a door were obstructed.
SR 3.6.13.4 Verifying, by visual inspection, that the ice condenser b- inlet doors are not impaired by ice, frost, or debris-provides assurance that the doors are free to open in the event of a DBA. For this unit, the Frequency of 18 months is based on door design, which does not allow water condensation to freeze, and operating experience, which indicates that the inlet doors very rarely fail to meet their SR acceptance criteria. Because of high radiation in the vicinity. of the inlet doors during power operation, this
. Surveillance is normally performed during a shutdown.
(continued) y a\
~jiMcGuireUnit1 B 3.6-90 Supplement' 2
_l a
r-Ico Cend:;nser D: ors B 3.6.13 BASES A{s_,}- . SURVEILLANCE SR' 3.6.13.5 REQUIREMENTS _ (continued) Verifying the opening torque of the-inlet doors provides assurance that no doors have become stuck in the closed position. The value of 675 in-lb is based on the design 2 openingpressureonthedoorsof1.0lb/ft. For this unit, the Frequency of 18 months is. based on the passive nature of the closing mechanism (i.e., once adjusted, there are no known factors that would change the setting, except possibly a buildup of ice; ice buildup is not likely, however, because of the door design, which does not allow water condensation to freeze). Operating experience indicates - that the inlet doors usually meet their SR acceptance criteria. Because of high radiation in the vicinity of the inlet doors during power operation, this Surveillance is normally performed during a shutdown. SR 3.6.13.6 The torque test Surveillance ensures that the inlet doors have not developed excessive friction and that the return springs are producing a door return torque within limits. 7 The torque test consists of the following: (V 1. Verify that the torque, T(0 PEN), required to cause opening motion at the 40' open position is s 195 in-lb;
- 2. Verify that the torque, T(CLOSE), required to hold the door stationary (i.e., keep it from closing) at the 40' open position is a 78 in-lb; and
- 3. Calculate the frictional torque, T(FRICT) = 0.5
{T(OPEN) - T(CLOSE)}, and verify that the T(FRICT) is s 40 in-lb. The purpose of the friction and return torque Specif) cations is to ensure that, in the event of a small break LOCA or SLB, all of the 24 door pairs open uniformly. This assures that, during the initial blowdown phase, the steam and water mixture entering the lower compartment does not pass through part of the ice condenser, depleting the ice there, while bypassing the' ice in other bays. The Frequency of 18 months is based on the passive nature of the closing mechanism th (continued) G McGuire Unit l' B 3.6-91 Supplement 2 l
Ica CcndInser Doors' B 3.6.13-
^ !> 1 BASES ;t SURVEILLANCE' SR 33.13.6-(continued)
REQUIREMENTS (i.e., once adjusted, there are no known factors that would change the setting, except possibly a buildup ef; ice; ice buildup is not likely, however..because of the door design, . 4 which does not allow water condensation to freeze). Operating experience indicates that the inlet doors very rarely fail to meet their.SR acceptance criteria. Because of high radiation in the vicinity of the inlet doors during
. power operation, this Surveillance is normally perfonned during a shutdown.'
SR 3.6.13.7 Verifying the OPERABILITY of the intermediate deck doors . provides assurance that the intermediate deck doors are free to open in the event of a DBA. The verification consists of visually inspecting the intermediate doors for structural deterioration, verifying free movement of the vent
. assemblies, and ascertaining free movement of each door when lifted with the; applicable force shown below:
D2gr Liftina Force
- a. Adjacent to crane wall < 37.4 lb
- b. Patred with door adjacent to crane wall s 33.8 lb
- c. Adjacent to containment wall s 31.8 lb
- d. Paired with door adjacent to containment s 31.0 lb wall The 18 month Frequency is based on the passive design of the intennediate' deck doors, the frequency of personnel entry into the intermediate deck, and the fact that SR 3.6.13.2 confirms on a 7 day Frequency that the doors are not impaired by ice, frost, or debris, which are ways a door would fail the opening force test (i.e., by sticking or from increased door weight).
REFERENCES 1. UFSAR, Chapter 6.
- 2. 10 CFR'50, Appendix K.
- 3. 10 CFR 50.36,. Technical Specifications, (c)(2)(ii).
I: q 4 B 3.6-92= Supplement 2
][lfMcGuire.. Unit 11 q
y
- t Divider Barrier Integrity.
3- B'3.6.14 B 3.6, CON 1;AINMENT SYSTEMS; f B'3.6'.14M Divider Barrier Integrity:
, BASES-BACKGROUND' The divider barrier consists of the operating deck-and-associated seals, personnel-access doors, and equipment hatches that separate the upper and lower containment-compartments. ' Divider barrier integrity is necessary to minimize bypassing of the ice condenser by the hot' steam and air mixture released into the lower compartment ~during a DesignBasisAccident(DBA). This ensures that most of the gases pass'through the ice bed, which condenses the steam and limits pressure and temperature during the accident transient. Limiting the pressure and temperature reduces the release of fission product radioactivity from containment to the environtent in the event of a DBA.
In the event of a DBA, the ice condenser inlet doors (located below the operating deck) open due to the pressure rise in the lower compartment. This allows air and steam to flow from the lower compartment into the ice condenser. The resulting pressure increase within the ice condenser causes the intermediate deck doors and the door panels at the top O of the condenser to open, which allows the air to flow out of the ice condenser into the upper compartment. The ice condenses the steam as it enters, thus limiting the pressure and temperature buildup in containment. The divider barrier separates the upper and lower compartments and ensures that the steam is' directed into the ice condenser. The ice, together with the containment spray, is adequate to absorb the initial blowdown of steam and water from a DBA as well as the additional heat' loads that would enter containment
.over several hours following the initial blowdown. The additional heat' loads would come from the residual heat in the reactor core, the hot piping and components, and the-secondary system, including the steam generators. During the post blowdown period, the Air Return System (ARS) returns upper compartment air through the divider barrier to the lower compartment. This serves to equalize pressures _in containment and to continue circulating heated air and steam from the lower compartment through the ice condenser, where
- the heat.is. removed by the remaining ice.
Divider barrier integrity ensures that the high energy fluids, released during a DBA would be' directed .through the
- p. (continued).
Q.-) __ McGuire Unit l'
~
B 3.6-93 Supplement 2 l
Divider Barrier Integrity B 3.6.14
' BASES'
- BACKGROUND' ice. condenser?and that the ice condenser would function as-
'm (continued)- designed if called upon to act as a passive' heat sink following.a DBA.
APPLICABLE ~ . Divider barrier integrity ensures the Lfunctioning of , SAFETY ANALYSES the ice condenser to the limiting containment pressure and temperature that could be experienced following a DBA. The limiting DBAs considered relative to containment tem and pressure are the loss of coolant accident-(LOCA)perature
.and the steam line break-(SLB). .The LOCA and SLB are analyzed'using computer codes designed to predict the resultant containment -
pressure and temperature transients. DBAs are assumed not-to occur simultaneously or consecutively. Although the ice condenser is a passive system th'at requires no electrical power to perform its function, the Containment Spray System, RHR Spray System, and the ARS also function to
- assist tM ice bed in limiting pressures and temperatures.
Therefort, the postulated DBAs are analyzed, with respect to containment Engineered Safety Feature (ESF) systems, assuming the loss of one ESF bus, which is the worst case single active failure and results in the inoperability of O one train in the Containment Spray S stem, RHR Spray System, and the ARS. Additionally, a 5.0 ft opening is conservatively assumed to exist in the divider plate in the LOCA.and SLB DBA analyses. The limiting DBA analyses (Ref.'1) show that the maximum . I peak containment pressure results from the LOCA analysis and is calculated.to be less than the containment design pressure. The maximum peak containment temperature results from the SLB analysis and is discussed in the Bases for LCO 3.6.5, " Containment Air Temperature." 3~ In addition to calculating the overall peak containment pressures, the DBA analyses include calculation of the' transient differential pressures that occur across subcompartment walls during the initial blowdown phase of l the. accident transient. The internal containment walls and I structures are designed to withstand these local transient
. pressure differentials for the limiting DBAs.
The divider barrier satisfies Criterion 3 of 10 CFR 50.36
- (Ref.2)..
.(continued)-
]:McGuireUnit;II :B 3.6-94 Supplement 2 I
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1 1 Divider. Barrier Integrity B 3.6.14 f-~ BASES (continued) V LC0 This LC0 establishes the' minimum equipment requirements to ensure that the divider barrier performs its safety function of ensuring that bypass leakage, in the event of a DBA, does not exceed the bypass leakage assumed in the accident analysis. Included are the requirements that the personnel access doors and equipment hatches in the divider barrier are OPERABLE and closed and that the divider barrier seal is properly installed and has not degraded with time. An exception to the requirement that the doors be closed is made to allow personnel, transit entry through the divider barrier. The basis of this exception is the assumption that, for personnel transit, the time during which a door. is ' open will be short (i.e., shorter than the Completion Time of I hour for Condition A). The divider barrier functions with the ice condenser to limit the pressure and temperature that could be expected following a DBA. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature requiring the integrity of the divider barrier. Therefore, the LC0 is applicable in MODES 1, 2, 3, and 4. O\ h The probability and consequences of these events in MODES 5 and 6 are low due to the pressure and temperature limitations of these MODES. As such, divider barrier integrity is not required in these MODES. ACTIONS Al If one or more personnel access doors or equipment hatches are inoperable or open, except for personnel transit entry, I hour is allowed to restore the door (s) and equipment hatches to OPERABLE status and the closed position. The 1 hour Completion Time is consistent with LC0 3.6.1,
" Containment," which requires that containment be restored to OPERABLE status within 1 hour.
Condition A has been modified by a Note to provide clarification that, for this LCO, separate Condition entry ; is allowed for each personnel access door or equipment ' hatch. 1 (continued) ! Q/ ' McGuire Unit 1 8 3.6-95 Supplement 2 l i
Divide'r. Barrier Integrity B 3.6.14
' BASES-ACTIONS Ed (continued).
If the divider barrier seal is inoperable, I hour is allowed to restore the seal to OPERABLE status. The 1 hour-Completion Time is consistent,with LCO 3.6.1, which requires that containment be restored to OPERABLE status within 1 hour. C.1 and C.2 If divider barrier integrity cannot be restored to OPERABLE status within the required Completion Time, the plant _ must
.be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 w'ithin 36 hours. ~The allowed Completion Times are reasonable, based ~on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR- 3.6.14.1 REQUIREMENTS j
+ Verification, by visual inspection, that all personnel i access doors and equipment hatches between the upper and lower containment compartments are closed provides assurance- ]
that divider barrier integrity is maintained prior to the reactor being taken from MODE 5 to MODE 4. This SR is necessary because many of the doors and hatches may have been opened for maintenance during the shutdown. SR 3.6.14.2
-Verification, by visual inspection, that the personnel access door and equipment hatch seals, sealing surfaces, and alignments are acceptable provides assurance that divider
. barrier integrity is maintained. -This inspection cannot be
. made when the door or hatch is closed. Therefore, SR 3.6.14.2 is required for each door or hatch that has been opened, prior to the final closure. Some doors and hatches may not. be opened -for long periods of time._ Those that use resilient' materials in the; seals must be_ opened and inspected-at least once every'10 years to provide assurance p, (continued) (,h . I l ~ McGuire Unit l ' B 3.6-96_ Supplement 2 x
Divider Barrier Integrity - B 3.6.14 m BASES q SURVEILLANCE SR 3.6.14.2-(continued)' ' REQUIREMENTS ~ that the seal material has-not aged to the ' point _ of degraded 1 performance. The Frequency of 10 years is based on the known resiliency of the materials used for seals, the-fact that the openings have not been opened (to cause. wear), and-operating experience that confirms that the seals inspected at this' Frequency have been found to be acceptable. SR 3.6.14.3 Verification, by visual inspection, after each opening of a personnel access door or equipment hatch that it has been closed makes the operator aware of the importance of closing it and thereby provides additional assurance that divider barrier integrity is maintained while in applicable MODES. SR 3.6.14.4 Conducting periodic physical property tests on divider barrier seal test coupons provides assurance that the seal material has not degraded in the containment environment, O including the effects of irradiation with the reactor at power. The required tests include a tensile strength test. The Frequency of 18 months was developed considering such factors as the known resiliency of the seal material used, the inaccessibility of the seals and absence of traffic in their vicinity, and the unit conditions needed to perform the SR. Operating experience has shown that these , components usually pass the Surveillance when performed at- i the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. 1 SR 3.6.14.5 Visual inspection of the seal around the perimeter provides assurance .that the seal is properly secured in place. The Frequency of 18 months was developed considering such factors as the inaccessibility of the seals and absence of 1 traffic in their vicinity, the strength of the bolts and mechanisms used to secure the seal, and the unit conditions needed to perform the'SR. Operating experience has shown p (continued) 'M ' McGuire Unit 1 .B 3.6 Supplement 2 l x:
- I Divider Barrier' Integrity-B 3.6.14 BASES O -
SURVEILLANCE ER 3.6.14.5 (continued) REQUIREMENTS { that these components usually pass the Surveillance when l performed at the 18 month Frequency. Therefore, the ~4 1 Frequency was concluded to be acceptable from a reliability standpoint. REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.36. Technical Specifications, '(c)(2)(ii).
1 Q i l i l l j i._,/ l..McGuireUnitl' B 3.6-98 Supplement 2 l ____i
l Containment Racirculation' Drains ; , B 3.6.15-IB 3.61 CONTAINMENT SYSTEMS
~
c B'3.6.15 Containment Recirculation Drains BASES BACKGROUND The containment recirculation drains consist of'the ice condenser drains and the refueling canal drains. The ice condenser is partitioned into 24 bays, each having a pair of inlet doors that open from the bottom plenum to allow the hot steam-air mixture from a Design Basis Accident (DBA) to - enter the ice condenser. Twenty of.the 24 bays have an ice condenser l floor drain at the bottom to drain the melted ice into the lower' compartment (in the 4 bays that do not have drains, the water drains .through the floor drains in the adjacentbays). Each drain leads to a drain pipe that drops down several feet, then makes one or more 90' bends and exits into the lower compartment. A check (flapper) valve at the end of each pipe keeps warm air from entering during normal operation, but when the water exerts pressure, it opens to allow the water to spill into the lower compartment. This prevents water from backing up and , interfering with the ice condenser inlet doors. The water I delivered to the lower containment serves to cool the O atmosphere as it falls through to the floor and provides a V source of borated water at the containment sump for long j term use by the Emergency Core Cooling System (ECCS) and the ; Containment Spray System during the recirculation mode of ' operation. The refueling canal drains are at low points in the refueling canal. During a refueling, valves are closed in the drains and the canal is flooded to facilitate the ! refueling process. The water acts to shield and cool the spent fuel as it is transferred from the reactor vessel to storage. After refueling, the canal is drained and the valves are locked open. In the event of a DBA, the refueling canal drains are the main return path to the lower compartment for Containment Spray System water sprayed into the upper compartment. The ice condenser drains and the refueling canal drains function with the ice bed, the Containment Spray System, and the ECCS to limit the pressure and temperature that could be expected following a DBA. (continued) McGuire. Unit'1- B 3.6-99 Supplement 2 ] h .( ' '.'
-~- -
.____.__.__.__.____1._____
Centainment Recirculation Drains B-3.6.15
~BASESL(continued)
O APPLICABLEr The limiting DBAs considered relative to containment SAFETY' ANALYSES temperature and pressure are the loss of coolant accident (LOCA) and the steam line break (SLB).1 The LOCA and SLB-are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients. DBAs are assumed not to occur simultaneously or consecutively. Although the ice condenser is a passive system that requires no electrical power to perform its function, the Contairenent Spray System and the Air Return System (ARS) also function to assist the ice bed in limiting pressures and temperatures. Therefore, the analysis of the postulated DBAs, with respect to Engineered Safety Feature (ESF) systems, assumes the loss of one ESF bus, which is the worst case single active failure and results in one train of the Containment Spray System and one train of the ARS being rendered inoperable. The limiting DBA analyses (Ref.1) show that the maximum peak containment pressure results from the LOCA analysis and is calculated to be less than the containment design pressure. . The maximum peak containment atmosphere temperature results from the SLB analysis and is discussed in the Bases for LCO 3.6.5, " Containment Air Temperature." In addition to calculating the overall peak containment O pressures, the DBA analyses include calculation of the transient differential pressures that occur across j
)
subcompartment walls during the initial blowdown phase of l the accident transient. The internal containment walls and l structures are designed to withstand these local transient 1 pressure differentials for the limiting DBAs. l The containment recirculation drains satisfy Criterion 3 of 10 CFR 50.36 (Ref. 2). LLC 0 This LCO establishes the minimum requirements to ensure that the. containment recirculation drains perform their safety functions. The ice condenser floor drain valve disks must
. be closed to' minimize. air leakage into and out of the ice condenser during normal operation and must open in the event
~
of a DBA when water begins to drain out. The refueling canal drain valves must be locked open and remain clear to ensure the return of Containment Spray System water to the lower containment in the event of a'DBA. The containment i _ ' recirculation drains' function with' the ice condenser, ECCS, ! p (continued) k/>
' ll McGuire UnitL 1 - B 3.6-100 Supplement 2 p l
L ] o i Containment Rtcirculaticn Drains B 3.6.15 , BASES
~LCO and Containment Spray System to limit the pressure and j
,(continued) temperature-that could be expected following a DBA.
i
' APPLICABILITY In' MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature, which would require the operation of the containment recirculation drains.
Therefore, the LCO is applicable in MODES 1, 2, 3, and 4. The probability and consequences of these events in MODES 5 and 6 are low due to the pressure and temperature-limitations of these MODES. As such, the containment recirculation drains are not required to be OPERABLE in these MODES. ACTIONS- M If one ice condenser floor drain is inoperable, I hour is allowed to restore the drain to OPERABLE status. The Required Action is necessary to return operation to within O the bounds of the containment analysis. The 1 hour (_)' Completion Time is consistent with the ACTIONS of LC0 3.6.1,
" Containment," which requires that containment be restored to OPERABLE status within 1 hour.
1L1 If one refueling canal drain is inoperable, I hour is all sed to restore the drain to OPERABLE status. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status in 1 hour. C.1 and C.2 If the affected drain (s) cannot be restored to OPERABLE status within the required Completion Time, the plant must (continued) sO.. McGuire Unit l B 3.6-101 Supplement 2 l
..i
Centainment Recirculation Drains B 3.6.15-BASES O. ACTIONS C.1 and C.2 (continued) be brought to a MODE in which the LCO does not apply. -To. achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions-from full power _ conditions in _an orderly manner and .without challenging plant systems. SURVEILLANCE SR 3.6.15.1 and SR 3.6.15.2 REQUIREMENTS Verifying the OPERABILITY of the refueling canal drains ensures that they will be able to perform their functions in the event of a DBA. SR 3.6.15.1-confirms that the refueling canal drain valves have been locked open and that the drains are. clear of any obstructions that could impair their functioning. In addition to debris near the drains, SR 3.6.15.2 requires attention be given to any debris that is-located where it could be moved to the drains in the event that the Containment Spray System is in operation and water is flowing to the drains. SR 3.6.15.1 must be performed-
\ before entering MODE 4 from MODE 5 after every filling of the canal to ensure that the valves have been locked open and that no debris that could impair the drains was deposited during the time the canal was filled. SR 3.6.15.2 j is performed every 92 days for the upper compartment and l refueling canal areas. The 92 day Frequency was developed q considering such factors as the inaccessibility of the drains, the absence of traffic in the vicinity of the drains, and the redundancy of the drains.
SR 3.6.15.3 Verifying the OPERABILITY of the ice condenser floor drains ensures that they will be able to perform their functions in the event of a DBA. Inspecting the drain valve disk ensures that the' valve is performing its function of sealing the drain line from warm air leakage into the ice condenser during normal operation, yet will open if melted ice fills
' the line following a DBA. Verifying that the drain lines are not obstructed ensures their readiness to drain water from the ice condenser. The 18 month Frequency was l
(continued) 7 l McGuire Unit'l B 3.6-102 Supplement 2 a _= - . . 1 i
Centainment R:circulaticn Drains B 3.6.15 BASES Q SURVEILLANCE SR ?.6.15.2 (continued) REQUIREMENTS developed considering such factors as the inaccessibility of the drains during power operation; the design of the ice condenser, which precludes melting and refreezing of the ice; and operating experience that has confirmed that the tirains are found to be acceptable when the Surveillance is perfonned at an 18 month Frequency. Because of high radiation in the vicinity of the drains during power operation, this Surveillance is normally done during a shutdown. REFERENCES- 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
O) 1
,-- s, . \.
McGuire Unit 1 B 3.6-103 Supplement 2 l
Reacter Building B 3.6.16 H- B 3.6 CONTAINMENT SYSTEMS
.Iu ) I B 3.6.16. Reactor Building ]
BASES . BACKGROUND The reactor building is a concrete structure that surrounds the steel containment vessel. Between the containment vessel and the reactor building inner wall is an annular space that collects containnent leakage that may occur following a loss of coolant accident (LOCA). This space i also allows for periodic inspection of the outer surface of the steel containnent vessel. The Annulus Ventilation System (AVS) establishes a negative pressure in the annulus between the reactor building and the steel containment vessel under post accident conditions. Filters.in the system then control the release of radioactive contaminants to the environment. The reactor I building is required to be OPERABLE to ensure retention of containment leakage and proper operation of the AVS. To ensure the retention of containment leakage within the ! reactor building:
- a. Each door in each ncess opening is closed except when
')
(O the access opening is being used for normal transit entry and exit, then at least one door shall be closed, and
- b. The sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) is OPERABLE.
l APPLIC/.BLE The design basis for reactor building OPERABILITY is a SAFETY ANALYSES LOCA. Maintaining reactor building OPERABILITY ensures that the release of radioactive material from the containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses. The reactor building satisfies Criterion 3 of 10 CFR 50.36 (Ref.1). 1 l (n) v. (continued) ! l .McGuire Unit 1 B 3.6-104 Supplement 2 l i
Reacter Building B 3.6.16 ; BASES l
? ~s ^
LCO Reactor building OPERABILITY must be maintained to ensure proper operation of the AVS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.
. APPLICABILITY Maintaining reactor building OPERABILITY prevents leakage of radioactive material from the reactor building. Radioactive material may enter the reactor building from the containment following a LOCA. Therefore, reactor building OPERABILITY is required in MODES 1, 2, 3, and 4 when a steam line break, LOCA, or rod ejection accident could release radioactive material to the containment atmosphere.
In MODES 5 and 6, the probability and consequences of these events are low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, reactor building OPERABILITY is not required in MODE 5 or 6. ACTIONS L1 In the event reactor building OPERABILITY is not maintained, reactor building OPERABILITY must be restored within 24 hours. -Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probability of a Design Basis Accident occurring during this time period. B.1 and B.2 If the reactor building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. '[w., (continued) McGuire Unit 1 B 3.6-105 Supplement 2 l [
l R: actor Building B 3.6.16 x) (N BASES SURVEILLANCE SR 3.6.16.1 REQUIREMENTS Maintaining reactor building OPERABILITY requires maintaining each door in the access opening closed, except when the access opening is being used for normal transit l entry and exit (then at least one door must remain closed). The 31 day Frequency of this SR is based on engineering judgment.and is considered adequate in view of the other indications of door status that are available to the operator. l SR 3.6.16.2 The ability of a AVS train to produce the required negative pressure within the requi ad times provides assurance that the building is adequately sealed. The negative pressure prevents leakage from the building, since outside air will be drawn in by the low pressure. The negative pressure must be established within the time limit to ensure that no significant quantity of radioactive material leaks from the reactor building prior to developing the negative pressure. O The AVS trains are tested every 18 months on a STAGSERED b TEST BASIS to ensure that in addition to the requirements of LC0 3.6.10. " Annulus Ventilation System," either AVS train will perform this test. The 18 month Frequency is based on the need to perform this Surveillance under the conditions I that apply during a plant outage. l SR 3.6.16.3 This SR would give advance indication of gross deterioration of the concrete structural integrity of the reactor building. The 40 month Frequency is based on the requirement to perform two additional inspections at approximately equal intervals between the Type A tests required by SR 3.6.1.1 performed on a 10-year interval. The verification is done during shutdown. REFERENCES 1. 10 CFR 50.36, Technical Specifications, (c)(2)(ii). p-LJ
-l McGuire Unit 1 B 3.6-106 Supplement 2 1
j
Cent'ainmentL
^ B 3.6.1 i
B'3.6 CONTAINMENT SYSTEMS.
'B 3.6.1' Containment ~
BASESe BACKGROUNO- The containment is a free' standing steel pressure vessel ~ surrounded by a reinforced concrete reactor building. - The containment vessel, including all its penetrations, is a low leakage steel shell designed to contain the radioactive-re: rial that may be released from the reactor core following a design basis Loss of Coolant Accident (LOCA). Additionally, the containment vessel and reactor building provide shielding from the fission products that may be present in the containment atmosphere following accident conditions. Ths-containment vessel is a vertical cylindrical steel pressure vessel with hemispherical dome and a flat circular base. It is completely enclosed by a reinforced concrete reactor building. An annular space exists between the walls and domes of the steel containment vessel and the concrete reactor building to provide for the collection, mixing, holdup, and controlled release of containment out leakage. Ice condenser containments utilize an outer concrete (- building for shielding and an inner steel containment for leak tightness. Containment piping penetration assemblies provide for the passage of process, service, sampling, and instrumentation pipelines into the containment vessel while maintaining containment integrity. The reactor building provides shielding and allows controlled release of-the annulus atmosphere under accident conditions, as well as environmental missile protection for the containment vessel and Nuclear Steam Supply System. The inner steel containment and its penetrations establish the' leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the
, . environment. SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions.
.The isolation devices for the penetrations in the containment boundary are a part of the containment leak i (continued) h J McGuire Unit 2 B 3.6-1 Supplement 2 l k
~
y: 1
Centainment
.B 3.6.1 BASES ~
BACKGROUND' . tight barrier. .To maintain this leak tight barrier: (continued)-
- a. All penetrations: required to be closed during accident
-conditions are either:
- 1 ~. . capable of being cloed by an OPERABLE automatic containment. isolation system,.or
- 2. closed by manual valves, blind flanges, or.-
de-activated automatic valves secured in their closed positions, except as 'provided in LCO 3.6.3, " Containment Isolation Valves";
- b. Each air lock is OPERABLE, except as provided in
'. l l LCO 3.6.2 " Containment Air Locks";
- c. All equipment hatches are closed; and
- d. The sealing mechanism associated with a penetration (e.g., welds, bellows, or 0-rings) is OPERABLE. -
APPLICABLE The safety design basis for the containment is that the O SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting Design Basis Accident (DBA) without exceeding the design'1eakage rates. The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures are a loss of coolant accident (LOCA) and a steam line break (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a LOCA. In the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of , fission product radioactivity, release to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage' rate of 0.3% of containment air weight per day (Ref. 3). This leakage rate, used in the evaluation of offsite doses resulting from accidents, is defined in.10 CFR 50, Appendix J ' (Ref. - 1), as L,: the maximum allowable - containment leakage rate at the calculated peak containment
- internal pressure (P ) resulting from the limiting design basis LOCA. _The allowable leakage rate represented by L, forms the basis for;the acceptance
.,- (continued) {
-ls McGuire Unit ' 2. B-3.6-2 Supplement 2
-Centainment
, B 3.6.1 BASES-
- APPLICABLE criteria imposed on-all containment leakage rate testing.
SAFETY ANALYSES L" =is14.8 assumed to be3). 0.3% peractory da in the safetyrate: analysis test at (continued) P psig (Ref. Satis leakage r$sults are a requirement for the. establishment of containment OPERABILITY. The containment satisfies- Criterion 3 of.10 CFR' 50.36 I (Ref.4). l LCO Containment OPERABILITY is maintained by limiting leakage to. s 1.0 L a requi., redexcept 10 CFR prior 50, to the firstJ,startup Appendix leakageafter test.performing At this time, the combined Type B and C leakage must be < 0.6 L., and the overall Type A leakage must be < 0.75 L,. Compliance with this LCO will ensure a containment configuration, including equipment hatches, that is structurally sound and that will. limit leakage to those leakage rates assumed in the safety analysis. Individual leaka lock (LCO 3.6.2)ge rates
, purge specified valves for the containment with-resilient seals, and air O reactor building bypass leakage-(LCO 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J. ' Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 L,.
APPLICABILITY In MODES 1,. 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature-limitations'of these MODES. Therefore, containment is not required to' be OPERABLE in MODE 5 to prevent' leakage of radioactive
~ material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.9.4, " Containment Penetrations."
(continued)
.McGuire Unit 2 B 3.6-3 . Supplement 2 l 4
1 Centainment j B 3.6.1 ! l .ig) BASES (continued) ACTIONS Al In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. 8.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance l with the visual examinations and Type A leakage rate test requirements of the Containment Leakage Rate Testing Program. Failure to meet specific leakage limits for the air lock, secondary containment bypass leakage path, and purge valve with resilient seals (as specified in LCO 3.6.2 and LCO 3.6.3) does not invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to overall Type A, B, rnd/or C4 leakage causes one of these overall leakage limits to be exceeded. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing l for overall Program leakage Type A leakage test is required following toor an outage beshutdown
< 0.75 L,t hat included Type A testing. At all other times between required leakage g _
(continued) Q,) l McGuire Unit 2 B 3.6-4 Supplement 2
Containment-B'3.6.1
' BASES:
SURVEILLANCE 'SR- 3.6.1.1^ (continued) REQUIREMENTS rate tests,' the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L*. At s 1.0 L the offsite dose consequences are bounded by the assumpti,ons of the safety analysis. SR Frequencies are as required by the Containment Leakage Rate Testing Program. These periodic
- testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.
The Surveillance is modified by a Note which requires that the space between'each dual-ply bellows assembly on . containment penetrations between the containment building-and the annulus be vented to the annulus during each' Type A test. SR 3.6.1.2 Maintaining the Containment OPERABLE requires compliance with the Type B and C leakage rate test requirements of 10 CFR 50, Appendix J, Option A (Ref.1), as raodified by approved exemptions. Failure to meet specific leakage O limits for the air lock, secondary containment bypass leakage path, and purge valve with resilient seals as specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to TypeA, Band /orCleakagecausesoneoftheseoverall leakage limits to be exceeded. As left leakage prior to~ the l first startup after performing a required 10 CFR 50, Appendix J Option A, leakege test is required to be
< 0.6 L, for combined Type B and C leakage. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L At s 1.0 L the offsite dose consequences are bounded,.by the assump,tions of the safety analysis. SR Frequencies are as required by Appendix J. Option'A,'as modified by approved exemptions. Thus,.SR 3.0.2 (which allows Frequency extensions) does not apply. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.
(continued) LO ;McGuire Unit 2 B 3.6-5 Supplement'2 l
~
4.. Centainment B 3.6.1 BASES SURVEILLANCE SR 3 . 6 .1. 7, (continued) REQUIREMENTS The Surveillance is modified by two Notes. Note I requires that following each Type A test, the space between each dual-ply bellows assembly be subjected to a low pressure leak test with no detectable leakage. Otherwise, the assembly must be tested with the containment side of the bellows assembly pressurized to P and meet the requirements. of SR 3.6.3.8 (bypass leakage req,uirements). Note 2 allows penetrations M372 and M373 to be tested without draining the glycol-water mixture from the associated diaphragm valves (NF-228A, NF-233B, and NF-234A) as long as no leakage is indicated. This test may be used in lieu of Section III.C.2(a) of 10 CFR 50, Appendix J, Option A which requires air or nitrogen as the test medium. The required test pressure and interval are not changed. All test leakage rates shall be calculated using observed data converted to absolute values. Error analysis shall also be performed to select a balanced integrated leakage measurement system. REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Chapter 15.
- 3. UFSAR, Section 6.2.
- 4. 10 CFR 50.36 Technical Specifications, (c)(2)(11).
[ %/ l McGuire Unit 2 8 3.6-6 Supplement 2
o ._ Containment Air' Locks-
'B 3.6.2 B 3.6L CONTAINMENT SYSTEMS-B 3.6.2; Containment Air Locks 1 BASES i'
BACKGROUND Containment air locks fonn part of the containment pressure boundary and provide a means- for personnel access during all MODES of operation. Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. Each air lock door has been designed and tested.to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY. Each of the doors contains double inflatable seals and local leakage rate testing capability to ensure pressure integrity. To effect a leak tight seal, the air lock design uses-pressure seated doors (i.e., an O increase in containment internal pressure results in increased sealing force on each rioor). Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided q to alert the operator whenever an air lock door interlock j mechanism is defeated. 1 The containment air locks. form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the. containment leakage' rate within limit in'the event of a'DBA. Not-maintaining air' lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analyses. (continued) McGuire Unit 2 B 3.6-7 Supplement 2 l-
Centainment Air Lecks
'B 3.6.2 BASES:(continued)
APPLICABLE The DBAs' that result in a release of radioactive material SAFETY ANALYSES within containment are a loss of coolant accident and a rod-ejection accident (Ref. 2). In the analysis of each ofL these accidents, it is assumed that containment is.0PERABLE-such that release of fission products to the environment is controlled by the rate of containment leakage.-. The-containment was designed with an allowable leakage rate of 0.3% of containment air weight per day (Ref. 2). . This leakage rate is defined in_10 CFR 50, Appendix J. (Ref.1), l as L = 0.30% of containment air weight per day, the maximum allowable. containment leakage rate at the calculated peak containment internal. pressure P, = 14.8 psig following a DBA. This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air locks. The containment air locks satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3). LCO Each containment air lock forms part of the containment pressure boundary. As part of the containment pressure boundary, the air lock safety function is related to control O of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.. Each air lock is required to be OPERABLE. . For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This
. provision ensures that a gross breach of containment does not exist when containmer.t is required to be OPERABLE.
Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events.
~ Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into or exit from containment.
APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of
' radioactive material to containment. In MODES 5 and 6, the (continued)
, f McGuire Unit 2 B 3.6-8 Supplement 2
Centainment Air Lecks-9 3.6.2 BASES APPLICABILITY probability and consequences of these events are reduced due (continued) to the pressure and temperature limitations of these MODES.. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the containment. air locks during_ MODE 6 are addressed in LCO 3.9.4, " Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock component. If the outer door is inoperable, then it may be easily accessed for most repairs. It is preferred that the air l lock be accessed from inside primary containment by entering through the other OPERABLE air lock. However, if this is not practicable, or if repairs on either door must be performed from the barrel side of the door then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door). The ability to open the OPERABLE door, even if it means the containment boundary is temporarily not 7 intact, is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open. After each entry and exit, the OPERABLE door must be immediately closed. If ALARA conditions permit, entry and exit should be via an OPERABLE air lock. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each air lock. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable air lock. Complying with the Required Actions may allow for continued operation, and a subsequent inoperable air lock is governed by subsequent Condition entry and application of associated Required Actions. In the event the air lock leakage results in exceeding the overall containment leakage rate, Note 3 directs entry into the applicable Conditions and Required Actions of LC0 3.6.1,
" Containment."
W (continued) h McGuire Unit 2 B 3.6-9 Supplement 2 l
Centainment' Air Locks B 3.6.2' BASESI
' ACTIONS 'A.11'A.2. and A.3:
(continued), With one air lock door in one or~more containment air locks inoperable, the OPERABLE door must be verified' closed (Required Action A.1); in each affected containment' air lock. This ensures that a leak tight containment barrier is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour. This' specified time period-is consistent with' the ACTIONS'of LCO 3.6.1, which requires containment be restored to OPERABLE status within I hour. In addition, the affected air lock penetration must be isolated by locking closed the OPERABLE. air lock door within the 24 hour Completion Time. The 24 hour Completion Time is reasonable for locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained closed. Required Action A.3 verifies that an air lock with an , inoperable door has been isolated by the use of a locked and J closed OPERABLE air lock door. This ensures that an ) acceptable containment leakage boundary is maintained. The Completion Time of once per 31 days is based on engineering O judgment and is considered adequate in view of the low likelihood of~a locked door being mispositioned and other l administrative controls. Required Action A.3 is modified by i a Note that applies to air lock doors located in high ] radiation areas and allows these doors to be verified locked 1 closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. The Required Actions have been modified by two Notes. Note 1 ene.ures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the I same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception of Note 1 does not affect-tracking the Completion Time from the initial entry into Condition A; only the requirement to comply with the Required Actions. Note 2 allows use of the air lock for (continued) j d McGuire Unit 2 B 3.6-10 Supplement 2
Centainment Air Lecks B 3.6.2 g BASES 'd ACTIONS A.I. A.2. and A.3 (continued) entry and exit for 7 days under administrative controls if both air locks have an inoperable door. This 7 day restriction begins when the second air lock is discovered inoperable. Containment entry may be required on a periodic basis to perform Technical Specifications (TS) Surve111ances and Required Actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e., non-TS-required activities) if the containment is entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is l acceptable due to the low orobability of an event that could pressurize the containment during the short time that the OPERABLE door is expected to be open. B.I. B.2. and B.3 With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated Q Completion Times are consistent with those specified in V Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the same air lock are inoperable. With both doors in the same air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock). Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. (continued) Y McGuire Unit ?,- B 3.6-11 Supplement 2 l
Centainment' Air Lccks-
- B 3.6.2 2 BASES-ACTIONS . .. C.I. C.2. and C.3-(continued)'
With one or more air locks: inoperable for reasons other than
' those described in Condition A or.B, Required Action C.I'.
requires action to be initiated insnediately. to evaluate - ~ previous combined: leakage rates using current air lock test results. An evaluation is acceptable since it is overly - conservative ~to immediately declare the containment inoperable if both doors in an air lock have. failed a seal test or if the overall air lock leakage is not within '
~
limits. In many instances (e.g., only one seal' per door has failed), containment remains OPERABLE, yet only 1 hour (per. LCO 3.6.1) would be provided to restore the air lock door to
. OPERABLE status prior to requiring a plant shutdown. In .-
addition, even with both doors failing the seal test, the-overall containment leakage rate can still be within limits. Required Action C.2 requires that one door in the affected containment air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status within , I hour. Additionally, .the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock. D.1 and D.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. ~ The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions- from full power conditions in an orderly manner and without challenging plant systems. (continued) l McGuire Unit 2: .B 3.6-12 Supplement 2
Centainment' Air Lecks--
- B 3.6.2
~
BASES;(continue'd) p/
' SURVEILLANCE SR3.6.2.1' REQUIREMENTS-Maintaining containment air locks OPERABLE requires
- compliance. with the leakage rate test requirements of' 10 CFR S0, Appendix J, Option A (Ref. 1), as modified by approved exemptions. This.SR reflects the^1eakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established
- during initial- air lock and containment OPERABILITY testing.
The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall. containment leakage rate. The Frequency is required by Appendix J, Option A (Ref. 1), as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply. The frequency required by_10 CFR 50 Appendix J. Option A, includes leak testing each door. seal within 72 hours of closing or every 72 hours when entries are being made more frequently. The seal annulus leakage must be < 0.01 L determined by precision flow measurements when measure, d foras at least 30 seconds with the pressure between the seals t P,. Overall airlock leakage tests are conducted at P every O 6 months. -.The overall air lock leakage rate must als,o be verified prior to establishing containment OPERABILITY. If the periodic 6-month test required Appendix J, Option A, is current, the seal leakage test may be substituted for the full pressure test provided no maintenance has been performed on an air lock. Whenever maintenance has been performed on an air lock, the requirements of paragraph III.D.2(b)(ii) of Appendix J, Option A must still be met. This is an exemption from 10 CFR 50, Appendix J Option A. The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of SR 3.6.1.2. This ensures that air lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate. (continued) 7y McGuire Unit 2 B 3.6-13 Supplement 2 l
Centainment Air Locks-B 3.6.2'
-BASES.
- l. SURVEILLANCE- 'SR 3.6.2.2 REQUIREMENTS
_(continued) Door. seals must be tested every 6 months to verify the integrity of the inflatable door seal. The measured leakage -{ rate must be less than 15 standard cubic centimeters per minute (sccm) per door seal when the seal is inflated to approximately 85 psig. This ensures'that the seals will-remain inflated for at least 7 days should the instrument air supply to the seals be lost. The Frequency of testing is consistent with the overall airlock leakage. tests required every 6 months by 10 CFR 50, Appendix J, Option A. (Ref. 1).
'l SR 3.6.2.3 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic O testing of this interlock demonstrates that the interlock-will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenges when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 18 months. The 18 month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the surveillance were performed with the reactor at power. The 18 month Frequency for the interlock is justified based on generic operating experience. The Frequency is based on engineering judgment and is considered adequate given that the interlock is not challenged during the use of the interlock.
REFERENCES 1. 10 CFR 50, Appendix J.
- 2. UFSAR, Section 6.2.
3.- 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
-lE McGuire Unit 2 B 3.6-14 Supplement 2 ;
j. _-_ _D
F , Centainment Isolaticn Valvts B 3.6.3
~B 3.6 CONTAINMENTLSYSTEMS-B 3.6.3 Containment' Isolation Valves-
' BASES:
BACKGROUND- The containment isolation valves fonn part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. These isolation devices are either passive or active (automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses. One of these barriers may be a closed system.- These barriers (typically containment isolation valves) make up the Containment Isolation System. Automatic isolation signals are produced during accident conditions. Containment Phase "A" isolation occurs upon receipt of a safety injection signal. The Phase "A" isolation signal isolates nonessential process lines in order to minimize leakage of fission product radioactivity. Containment Phase "B" isolation occurs upon receipt of a containment pressure High-High signal and isolates the remaining process lines, except systems required for accident mitigation. In addition to the Phase "A" isolation signal, the purge and exhaust valves receive an isolation signal on a containment high radiation condition. As a result, the containment isolation valves (and blind flanges) help ensure that the containment atmosphere will be isolated from the environment in the event of a release of fission product radioactivity to the containment atmosphere as a result of a Design Basis Accident (DBA). The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the p (continued) M McGuire Unit'2l .B 3.6-15 Supplement 2 l
Containment Isolaticn Valvas B 3.6.3 BASES w BACKGROUND time limits assumed in the safety analyses. Therefore, the (continued) OPERABILITY requirements provide assurance that the containment function assumed in the safety analyses will be maintained. Containment Purae System The Containment Purge System operates to supply outside air into the containment for ventilation and cooling or heating and may also be used to reduce the concentration of noble gases within containment prior to and during personnel access. There are five purge air supply line penetrations and four exhaust penetrations in the containment. The supply penetrations include one line through the reactor building wall, two through the containment vessel into upper containment, and two lines through the containment vessel into lower containment. The exhaust penetrations include two lines through the containment vessel out of upper containment, one line through the containment vessel out of lower containment, and one line through the reactor building
/~'s wall. Two normally closed isolation valves at each V containment vessel penetration provide containment isolation.
The upper containment purge portion of the system has the capability to operate when periods of sustained personnel access are required. This is allowed for normal operation (MODES 1-4), provided no more than one pair (one supply and one exhaust flow path) are open at one time. The upper containment supply and exhaust are also operated during I refueling operation (MODES 5-6). The exhaust portion helps to reduce the consequences of a fuel handling accident in containment by removing and filtering any airborne radioactive effluents that may result from a fuel handling accident. The lower containment purge is only used during refueling operations because if these lines were used during normal operation, they may not close in the event of a LOCA. APPLICABLE The containment isolation valve LCO was derived from the SAFETY ANALYSES assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary
.g (continued) 1 L.J l l McGuire Unit 2 B 3.6-16 Supplement 2 i i
V I
;Centainment Isolaticn Valves B 3.6.3 BASEF-APPLICABLE 'during major accidents. As'part of the containment-SAFETY ANALYSES boundary, containment isolation valve OPERABILITY supports (continued) leak tightness of the containment.. Therefore, the safety analyses of any event requiring isolation of containment is
, applicable -to this LCO.-
The DBAs that result in a release of radioactive material. within containment are a loss of coolant accident (LOCA) and a rod ejection accident'(Ref. 1). In the analyses for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through-containment isolation valves (including containment purge - valves) are minimized. The safety analyses assume that the lower compartment and instrument room purge valves are closed at event initiation. The DBA analysis assumes that, within 76 seconds after the accident, isolation of the containment is complete and , leakage terminated except for the design leakage rate, L.. ; The containment isolation total response time of 76 seconds includes signal delay, diesel generator startup (for loss of 1 offsite power), and containment isolation valve stroke O times. The single failure criterion required to be imposed in the conduct of plant safety analyses was considered in the original design of the containment purge valves. Two valves in series on each purge line provide assurance that both the supply and' exhaust lines could be isolated even if a single failure occurred. The lower and instrument room purge valves may be unable to close in the environment following a LOCA. Therefore, each of the lower and instrument room purge valves is required to remain sealed closed during MODES 1, 2, 3, and 4. The upper purge valves may be opened for ALARA considerations. In this case, the single failure criterion remains applicable to the containment purge valves due to failure in the control circuit associated with each valve. Again, the purge system valve design precludes a single failure from l i (continued) O : McGuire Unit 2 B 3.6-17 Supplement 2
)
l ! ~ _ _ . . . . . . . .. _rl
Centainment Isolation Valves-B 3.6.3 BASES APPLICABLE compromising the containment boundary as long as the system . SAFETY ANALYSES is operated in accordance with.the subject LCO. !
.(continued)
The containment isolation valves satisfy Criterion 3 of 10 CFR 50.36 (Ref. 2). LCO Containment isolation valves form a part of the containment boundary. The containment isolation valves' safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA. The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The lower compartment and instrument room purge valves must be maintained sealed closed. The valves covered by this LC0 are listed alon with.their associated stroke times in the UFSAR (Ref. 3 . The normally closed isolation valves are considered OPERABLE when man"al valves are closed, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed systems are intact. These passiveisolationvalves/devicesarethoselistedin Reference 1. Purge valves with resilient seals and reactor building bypass valves must meet. additional leakage rate requirements. The other containment isolation valve leakage rates are addressed by LCO 3.6.1, " Containment," as Type C testing. This LCO provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required ,47
.i g (continued) lL McGuire Unit 2 8 3.6-18 Supplement 2 a
Centainment Isolatien Valves B 3.6.3 BASES f3 APPLICABILITY to be OPERABLE in MODE 5. The requirements for containment (continued) isolation valves during MODE 6 are addressed in LCO 3.9.4,
" Containment Penetrations."
ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, except for lower containment purge supply and exhaust valves for the lower compartment and instrument room, to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous comunication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. For valve controls located in the control room, an operator may monitor containment isolation signal status rather than be stationed at the valve controls. Due to the * ? of the containment purge line penetration and the fac. mat those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls. A single purge valve in a penetration flow path may be opened to effect repairs to an inoperable valve, as allowed by I SR 3.6.3.1. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions. The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. In the event the containment isolation valve leakage results in exceeding the overall containment leakage rate, Note 4 directs entry into the applicable Conditions and Required Actions of LC0 3.6.1. o (continued) McGuire Unit 2 B 3.6-19 Supplement 2 l
Ccntainment Isolaticn Valves B 3.6.3 n BASES ( ACTIONS A.1 and A.2
-(continued)
In the event one containment isolation valve in one or more penetration flow paths is inoperable except for purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve inside containment with flow through the valve secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time e nd (3 that have been isolated in accordance with Required y/ Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation ' devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility, n (continued) b l McGuire Unit 2 B 3.6-20 Supplement 2
e . CentNnmentIsolationValvas-B 3.6.3 o BASES
. ACTIONS A.1 and A.2' (continued) l i
~
Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths-with two containment isolation valves. For. penetration flow paths with only one containment isolation valve and a closed-system, Condition C provides the appropriate actions. Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows. these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices once they have been verified to be in the proper position, is small. Ild With two containment isolation valves in one or more penetration flow paths inoperable, except for the purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated within O 1 hour. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1. In the event the.affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low. Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves. Condition A of this LCO (continued) McGuire Unit 2 .B 3.6-21 Supplement 2 l
Centainment = Isolaticn Valves s B 3.6.3 BASESL ACTIONS B.1 and B.2 (continued) addresses the condition of one containment isolation valve-inoperable. in this type of penetration flow path. C,1 and C.2 With one or more penetration flow paths with one containment isolation valve inoperable, the inoperable valve flow path
-must be restored to OPERABLE status or the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by.a' single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to isolate the affected penetration flow path. Required Action C.1 must be completed within the 72 hour Completion Time. The specified time period is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of maintaining containment integrity during MODES 1, 2, 3, and 4. In the event the affected O penetration-flow path is isolated in accordance with Required Action C.1, the affected penetration flow path must be verified to be isolated on a periodic basis. This periodic verification is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion' Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low, Condition C is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with only one containment isolation valve and a closed system. The closed system must meet the requirements of Reference 5. This Note is necessary since this Condition is written to specifically address those penetration flow paths in a closed system.
Required Action C.2 is modified by a Note that applies to valves'and blind flanges located in high radiation areas and allows these devices to be verified closed by use of . ,y (continued) G B 3.6-22 Supplement 2 l McGuire Unit 2'
Centainment Isolaticn Valves - B 3.6.3 BASESI k) ACTIONS- C.1~andC.2l(continued). administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. D.d With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the. leakage must be restored to within limit within 4 hours. Restoration can be accomplished by-isolating the penetration (s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to. isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 4 hour Completion Time is reasonable considering the time required to restore the leakage by isolating the O penetration (s) and the relative importance of secondary containment bypass leakage to the overall containment function. Ll. E.2. and E.3 In the event one or more purge valves for_ upper and lower containment or instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method'of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active
. failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. A valve with resilient seals utilized to satisfy Required Action E.1 must have been
'. demonstrated to meet the leakage requirements of SR 3.6.3.6. l The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist.
(continued) McGuire Unit 2 B 3.6-23 Supplement 2 l 1 x
Centainment Isolation Valves B 3.6.3' d'
-BASES-ACTIONS E'.1. E.2. and E.3 - (continu'ed)
In accordance with Required Action E.2, this penetration flow path must-be verified to be isolated on a periodic. basis. LThe periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being-automatically _ isolated,~will be in the isolation position shoulti an event occur. This Required Action does not require any testing or valve manipulation. Rather, it-l involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. Fur the isolation devices inside containment, the time period'specified as " prior to entering MODE 4 from MODE'S if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that' isolation device misalignment is an unlikely possibility. For the containment purge valve with resilient seal that is isolated in accordance with Required Action E.1, SR 3.6.3.6 O- l_ must be performed at least once every 92 days. This assures that degradation of the resilient seal _is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration i3 isolated. F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply. ' To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 : within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant syscems, l
)
(continued) l lc McGuire Unit 2! B 3.6-24 Supplement 2
~-
I Containment Isolation Valvas B 3.6.3 BASES (continued) SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge valve for the lower compartment and instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious cpening of a containment purge valve. Detailed analysis of these valves to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses has not been performed. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term " sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance permits opening one purge valve in a penetration flow. path to perform repairs. O b SR 3.6.3.2 This SR ensures that the containment purge supply and exhaust isolation valves for the upper compartment are closed as required or,1f open, open for an allowable reason. If a valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed it is not considered to have leakage cMside of limits. The SR is not required to be met when the valves are open for the l reasons stated. The valves may be opened for pressure l control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment 1 olation valve requirements discussed in SR 3.6.3.3. l I
-Q (continued)
L/ McGuire Unit 2 B 3.6-25 Supplement 2 l
Centainment Isolaticn Valvas B 3.6.3 BASES (continued) , i l l SURVEILLANCE SR 3.6.3.3 ; REQUIREMENTS l (continued) This SR requires verification that each cor+ainment ! isolation manual valve and blind flange located outside l l containment or annulus and not locked, sealed, or otherwise secured and required to be closed during .?.ccident conditions i is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve mar.ipulation. Rather, it l involves verification..through a system walkdown or computer j status indication, that those containment isolation valves ; outside containment and capable of being rispositioned are ! in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically , restricted during MODES 1, 2, 3 and 4 for ALARA reasons, j Therefore, the probability of misalignment of these t containment isolation valves, once they have been verified to be in the proper position, is small. l SR 3.6.3.4 This SR requires verification that each containment isolation manual valve and blind flange located inside 1 l ' containment or annulus and not locked, sealed, or otherwise )' secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the
- (continued) f J
l McGuire Unit' 2 B 3.6-26 Supplement 2 1
. l
- 1 Centainment Isolaticn Valves B 3.6.3 BASES- (continued)
SURVEILLANCE SR 3.'6.3.4 (continued) REQUIREMENTS Frequency of " prior to entering MODE 4 from MODE 5 if not. perfonned within the previous 92 days"'is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. ' The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked,' sealed, or.otherwise secured in the closed position, since these_ were veriNed-to'be the correct position upon locking, sealing, or securing. This' Note allows valves and blind flanges _ located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access-to these areas is typically restricted during MODES 1, 2, 3,
'and 4. for ALARA reasons. -Therefore, the probability of misalignment.of these containment isolation valves, once they have been. verified to be in their proper position, is small.
SR 3.6.3.5 l Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program. SR -3.6.3.6 l For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, is required to ensure OPERABILITY. The measured leakage rate for containment purge lower compartment and instrument room valves must l,e s 0.05 L, I when pressurized to P,. The measured leakage rate for containment-purge upper compartment valves must be s 0.01 L, when pressurized to P,. Operating experience has I (continued)~ McGuire Unit 2c 8 3.6-27 Supplement 2 l 7
Containment Isolatien Valves B 3.6.3. BASES (continued) SURVEILLANCE SR 3.6.3.6-- (continued) REQUIREMENTS ~ demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment) a Frequency of 184 days _was established. The containment purge upper compartment valves may be-used during normal operation, therefore, in addition to the 184 day Frequency, this SR must he performed every 92 days after-opening the valves. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened. The containment purge lower compartment valves and instrument room valves remain closed during normal operation and this SR is only performed every 184 days for these valves. l SR 3.6.3.7 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this. Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. (continued)
] LMcGuire Unit 2 8 3.6-28 Supplenent 2 j
Centainment Isolation Valves B 3.6.3
' BASES (continued)
O SURVEILLANCE- SR -3.6.3.8- l REQUIREMENTS . (continued). This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal-to the specified leakage rate. This provides assurance that. the assumptions in the safety analysis are met. The leakage-frate of each bypass-leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the
.two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of- the isolated bypass leakage path-is assumed' to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the-actual leakage rate is the lesser leakage rate of the two valves. This method of quantifying maximum pathway leakage is only to be used for this SR (i.e., Appendix J maximum pathway leakage limits are to be quantified in accordance with Appendix J). Penetrations which are not individually testable shall be determined to have_no detectable leakage when tested with soap bubbles while the containment is pressurized during SR 3.6.1.1 Type A testing. The Frequency for penetrations which are individually testable is required by 10 CFR 50, Appendix J,_as modified by approved exemptions (and therefore. the Frequency extensions of SR 3.0.2 may not be applied), since the testing is an Appendix J. Type B or C l test. This SR simply imposes additional acceptance criteria.
Bypass leakage is considered part of L,. REFERENCES 1. UFSAR, Section 15.
- 2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 3. UFSAR, Section 6.2.
~
- 4. Generic Issue B-24.
- 5. ' Standard Review Plan 6.2.4.
'McGuire Unit 2 B 3.6-29 Supplement 2 l I
(continued)
' Containment Pressure-B 3.6.4
.B 3.6 CONTAINMENT SYSTEMS B 3.6.4 Containment Pressure BASES BACKGROUND The containment pressure is limited during normal operation to preserve the initial conditions' assumed in the accident analyses for a loss of coolant accident (LOCA).or. steam line break (SLB). These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere following an event which has the potential to result in a net external pressure on the' containment.
Containment pressure is a process variable'that is monitored ' and controlled. The containment pressure limits are derived from the input conditions used in the containment functional analyses and the containment structure external pressure analysis. -Should operation occur outside these limits O coincident with a Design Basis Accident (DBA), post accident containment pressures could exceed calculated values. APPLICABLE Containment internal pressure is an initial condition used SAFETY ~ ANALYSES- in the DBA analyses to establish the maximum peak containment internal pressure. The limiting DBAs considered, relative to containment pressure, are the LOCA and SLB, which are analyzed using computer codes designed to predict the resultant. containment pressure transients. The worst case LOCA generates larger mass and energy release than the worst case SLB. Thus, the LOCA event bounds the SLB event from the containment peak pressure standpoint (Ref. 1). The initial pressure condition used in 'the containment analysis was 15.0 psia (0.3 psig). The containment analysis (Ref.1) shows that the maximum peak calculated containment _' pressure, P., results from the limiting LOCA. The maximum containment pressure resulting from the worst case LOCA does not exceed the containment design pressure 15.0 psig. (continued) lcMcGuise Unit 2: 'B_3.6-30 Supplement 2 x
,/,
Centainment Pressura B 3.6.4 g BASES (continued) d APPLICABLE The containment was also designed for an external pressure SAFETY ANALYSES load equivalent to -1.5 psig. (continued) There are four conditions which have a potential for resulting in a net external pressure on the containment:
- 1. Rupture of a hot or high pressure process pipe in the annulus.
- 2. Inadvertent Containment Spray System initiation'during normal operation.
- 3. Inadvertent containment air return fan initiation during normal operation.
- 4. Containment purge fan operation with containment purge J inlet valves closed. ;
1 The containment design of 1.5 psig negative is not violated in the above conditions due to either equipment limitations or design features. For certain aspects of transient accident analyses, (5 maximizing the calculated containment pressure is not ( ' conservative. In particular, the cooling effectiveness of the Emergency Core Cooling System during the core reflood phase of a LOCA analysis increases with increasing tontainment backpressure. Therefore, for the reflood phase, j the containment backpressure is calculated in a manner j designed to conservatively minimize, rather than maximize, I the containment pressure response in accordance with 10 CFR 50, Appendix K (Ref. 2). Containment pressure satisfies Criterion 2 of 10 CFR 50.36 (Ref. 3). LC0 Maintaining containment pressure at less than or equal to the LCO upper pressure limit ensures that, in the event of j a DBA, the resultant peak containment accident pressure will i remain below the containment design pressure. Maintaining containment pressure at greater than or equal to the LC0
,w - (continued) 1 )
M/ McGuire Unit 2 B 3.6-31 Supplement 2 l l 1 i _____._______________________j
l 1 Containment Pressura j B 3.6.4 q fm BASES (continued) U LCO lower pressure limit ensures that the containment will not (continued) exceed the design negative differential pressure following an event which has the potential to result in a net external pressure on the containment. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. Since maintaining containment pressure within limits is essential to ensure initial conditions assumed in the accident analyses are maintained, the LC0 is applicable in MODES 1, 2, 3 and 4. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment pressure within the limits of the LC0 is not required in MODE 5 or 6. ACTIONS Ad When containment pressure is not within the limits of the
'O. LCO, it must be restored to within these limits within 1 hour. The Required Action is necessary to return operation to within the bounds of the containment analysis.
The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1, " Containment," which requires that containment be restored to OPERABLE status within 1 hour. B.1 and B.2 If containment pressure cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least I MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. .o (continued) l l McGuire Unit 2 B 3.6-32 Supplement 2
Centainment Pressura B 3.6.4 BASES (continued)' SURVEILLANCE SR 3.6.4.1 REQUIREMENTS Verifying that containment pressure is within limits ensures that unit operation-remains within-the limits assumed in the containment analysis. .The 12 hour Frequency of_this SR was developed based on operating experience related to trending _ of containment pressure variations during the applicable MODES. Furthermore, the 12 hour Frequency is. considered adequate in view of other indications available in the control room,~ including alarms, to alert the operator to an abnormal containment pressure condition. REFERENCES 1. UFSAR, Section 6.2. 2.- 10 CFR 50 Appendix K.
- 3. 10 CFR 50.36. Technical Specifications, (c)(2)(ii).
O O ;_McGuire Unit 2. B 3.6 Supplement 2 l c; >
Centainment Air Temp 2rature B 3.6.5 -f 8 3.6 CONTAINMENT SYSTEMS B 3.6.5 Containment Air Temperature
. BASES BACKGROUND The containment structure serves to contain radioactive material that may be released from the reactor core following a Design Basis Accident (DBA). The containment average air temperature is limited, during normal operation, to preserve the initial conditions assumed in the accident analyses for a loss of coolant accident (LOCA) or steam line break (SLB).
The containment average air temperature limit is derived - from the input conditions used in the containment functional analyses and the containment structure external pressure analyses. This LCO ensures that initial conditions assumed in the analysis of containment response to a DBA are not violated during unit operations. The total amount of energy to be removed from containment by the Containment Spray and ECCS systems during post accident conditions is dependent upon the energy released to the containment due to the event, as well as the initial containment temperature and O pressure. High initial temperature, results in a higher ( peak containment temperature. Low initial temperature results in a higher peak containment pressure. Exceeding containment design pressure may result in leakage greater than that assumed in the accident analysis. Operation with containment temperature in excess of the LC0 limit violates an initial condition assumed in the accident analysis. APPLICABLE Containment average air temperature is an initial condition SAFETY ANALYSES used in the DBA analyses that establishes the containment environmental qualification operating envelope for both pressure and temperature. The limit for containment average air temperature ensures that operation is maintained within the assumptions used in the DBA analyses for containment (Ref. 1). .p (continued)
- (_,)
l McGuire Unit 2 8 3.6-34 Supplement 2
Containment Air Temperature B 3.6.5 BASES APPLICABLE The limiting DBAs considered relative to containment SAFETY ANALYSES OPERABILITY are the LOCA'and SLB. The DBA LOCA and'SLB are (continued) analyzed using computer codes designed to predict the resuitant containment pressure and temperature transients. No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed with regard to Engineered Safety Feature (ESF) systems,' assuming the loss of one ESF bus, which is the worst case single active failure, resulting in one train each of Containment Spray System, Residual Heat Removal System, and Air Return System being rendered inoperable. The limiting DBA for the maximum peak containment air temperature is an SLB. For the upper compartment, the
, initial containment average air temperature assumed in the~
design basis analyses (Ref. 1) is 100*F. For the lower compartment, the initial average containment air temperature - assumed in the design basis analyses is 135'F. This resulted in a maximum containment air temperature of 317'F. The current environmental qualification temperature limit is 341*F. The temperature upper limits are used to establish the environmental qualification operating envelope for both O containment compartments. The maximum peak containment air temperature for both containment compartments was calculated to be within the current environmental qualification temperature limit during the transient. The basis of the containment environmental qualification temperature is to ensure the performance of safety related equipment inside containment (Ref. 2). The temperature upper limits are also used in the depressurization analyses to ensure that the minimum pressure limit ~is maintained for both containment compartments following an event which has the potential to result in a net external pressure on the containment. The containment pressure transient is sensitive to the initial air mass in containment and, therefore, to the initial containment air temperature. The limiting DBA for establishing the maximum peak containment internal pressure (continued) McG0 ire Unit:2- B 3.6-35 Supplement 2 l
Centainment Air Temperature j B 3.6.5 j BASES APPLICABLE is a LOCA. The temperature lower limits, 70*F for the upper SAFETY ANALYSES compartment and 100*F for the lower compartment, are used in (continued) this analysis to ensure that, in the event of an accident, the maximum containment internal pressure will not be exceeded in either containment compartment. Containment average air temperature satisfies Criterion 2 of 10 CFR 50.36 (Ref. 3). LC0 During a DBA, with an initial containment average air temperature within the LC0 temperature limits, the resultant peak accident temperature is maintained below the containment environmental qualification temperature. As a result, the ability of containment to perform its design function is ensured. Two Notes to the LCO provide containment air temperature flexibility. Note 1 establishes that in MODES 2, 3, and 4, containment air temperature may be as low as 60*F because the resultant calculated peak containment accident pressure would not exceed the design pressure due to a lesser amount of energy released from the pipe break in these MODES. Note 2 allows the containment . r3 lower compartment temperature to be between 120 and 125'F V for up to 90 cumulative days per calendar year provided the lower compartment temperature average over the previous 365 days is less than 120*F. Within this 90 cumulative day period, lower compartment temperature may be between 125*F and 135"F for 72 cumulative hours. These exceptions are necessary during peak lake temperature periods when service water temperatures increase. A failure of a containment air handling unit concurrent with peak service water temperatures could exceed the normal lower compartment temperature limit. The exception provides a limited period of time to effect repairs and avoid a forced unit shutdown. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperatt:re within the limit is not required in MODE 5 or 6. J . ), (continued) Q B 3.6-36 l- McGuire Unit 2 Supplement 2
Centainment Air Temp 2rature : B 3.6.5 BASES ACTIONS M When containment average air' temperature _in the upper 'or-
. lower compartment is.not within the limit of the LCO,;the average' air temperature in.the affectedl compartment'must be restored to within limits within 8 hours.--:This Required Action is necessary to return operation to within the bounds
'of the containment analysis. The' 8 hour Completion Time is-acceptable considering the sensitivity of the analysis to-variations in this parameter and provides sufficient time to correct minor problems.
B.1 and B.2 If the containment average air temperature cannot_be restored to within its limits within the required Completion Time, the plant must_be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought.to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times 'are reasonable, based on operating experience, to reach _ the required plant conditions from full power conditions in an
;- 1 orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.6.5.1 and SR 3.6.5.2 REQUIREMENTS Verifying that containment average air temperature is within the LC0 limits ensures that containment operation remains within the limits assumed for the containment analyses. In order to determine the containment average air temperature, a weighted average of ambient air temperature monitoring stations is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere. The weighted average is the sum of each temperature multiplied by its respective containment volume fraction. In the event of inoperative temperature sensor (s), the weighted average shall be taken as the reduced total, divided by one minus the volume fraction represented by the. sensor (s) out of_ service. The upper compartment measurements should be taken at elevation 826 feet at the inlet of each upper containment ventilation unit. The lower compartment measurements should , i be taken at elevation 745 feet at the inlet of each lower-(continued) 0 ?McGuire Unit 2 'B 3.6-37 Supplement 2 l-g ,
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I j
Ccntainment Air Temperature B 3.6.5 BASES SURVEILLANCE' SR 3.6.5.1 AND SR 3.6.5.2 (continued)' REQUIREMENTS containment ventilation unit. The 24 hour Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition. REFERENCES 1. UFSAR, Section 6.2.
- 2. 10 CFR 50.49.
- 3. 10 CFR 50.36 Technical Specifications, (c)(2)(ii).
O I
; .f : (continued)
, J, l LMcGuire Unit 2 - B 3.6-38 Supplement 2
x. 1 Containment Spray System B 3.6.6' B 3.6, CONTAINMENT SYSTEMS lf- - B 3.6.6 Containment Spray System BASES BACKGROUND The Containment Spray System provides containment atmosphere cooling to limit post accident pressure and temperature in, i containment to less than the design values.- Reduction of i containment pressure and the iodine removal _ capability of the spray reduce the release of fission product . radioactivity from containment to the environment, in the event of a Design Basis Accident-(DBA). The Containment Spray System.is designed to meet the requirements of > 10 CFR 50, Appendix A. GDC 38, " Containment Heat. Removal," GDC 39, " Inspection of Containment Heat . Removal Systems," GDC 40,'" Testing of Containment Heat Removal Systems," GDC 41, " Containment Atmosphere Cleanup," GDC 42,
" Inspection of Containment Atmosphere Cleanup Systems," and GDC 43, " Testing of Containment Atmosphere Cleanup Systems" (Ref. 1).
The Containment Spray System consists of two separate trains-of equal capacity, each capable of meeting the system design basis spray coverage. Each train includes a containment spray pump, one containment spray.-heat exchanger, spray headers, nozzles, valves, and piping. Each train is powered from a separate Engineered Safety Feature (ESF) bus. The refueling water. storage tank (RWST) supplies borated water to the Containment Spray System during the injection phase of operation. In the recirculation mode of operation, containment spray pump suction is transferred from the RWST to the containment recirculation sump (s). The diversion of a portion of the recirculation flow from each train of the Residual Heat Removal (RHR) System to additional redundant- spray headers completes the Containment Spray System heat removal capability. Each RHR train is capable of supplying spray coverage, if required, to supplement the Containment Spray System.
'l (continued) b' LMcGuire Unit 2 B 3.6-39 Supplement 2 l e
o
Centainment Spray System B 3.6.6 BASES BACKGROUND The Containment Spray System and RHR System provide a spray (continued) of cold or subcooled borated water into the upper containment volume to limit the containment pressure and temperature during a DBA. The RWST solution temperature is an important factor in determining the heat removal capability of the Contuinment Spray System during the injection phase. In the recirculation mode of operation, heat is removed from the containment sump water by the Containment Spray System and RHR heat exchangers. Each train of the Containment Spray System, supplemented by a train of RHR spray, provides adequate spray coverage to meet the system design requirements for containment heat removal. For the hypothetical double-ended rupture of a Reactor Coolant System pipe, the pH of the sump solution (and, consequently, the spray solution) is raised to at least 8.0 within one hour of the onset of the LOCA. It is possible to adjust the pH of the sump solution using the chemical mixing tank and the charging pumps, should it become necessary. The alkaline pH of the containment sump water minimizes the evolution of iodine and the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid. The Containment Spray System is actuated either automatically by a containment pressure high-high signal or manually. An automatic actuation opens the containment spray pump discharge valves, starts the two containment spray pumps, and begins the injection phase. A manual actuation of the Containment Spray System requires the operator to actuate two separate train related switches on the main control board to begin the same sequence of two train actuation. The injection phase continues until an RWST level Low-Low alarm is received. The Low-Low alarm for the RWST signals the operator to manually align the system to the recirculation mode. The Containment Spray System in the recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the operator in accordance with the emergency operation procedures. (continued) LJ l McGuire Unit 2 B 3.6-40 Supplement 2
.Ccntainment Spray System B 3.6.6-BASES-
' BACKGROUND' The'RHR spray operation.is initiated manually, when required (continued) by the emergency operating procedures, after the Emergency Core Cooling System (ECCS) is operating in the recirculation mode. The RHR sprays are available to supplement the-Containment Spray System.. if required, in limiting containment pressure. This additional spray capacity would:
typically be used after the ice bed has been depleted and in the event that containment pressure rises above a predetermined limit. The Containment Spray System is an ESF system. It'is designed.to ensure that the heat removal capability required during the post accident period can be attained. The operation of the Containment Spray _ System, together with the ice condenser, is adequate to assure pressure suppression subsequent to the initial blowdown of steam and water from a DBA. During the post blowdown period, the Air Return System (ARS) is automatically started. The ARS returns upper compartment air through the divider barrier to the lower compartment. This serves to equalize pressures in containment and to continue circulating heated air and steam through the ice condenser, where heat is removed by the remaining. ice. The Containment Spray System limits the temperature and pressure that could be expected following a DBA. Protection of containment integrity limits leakage of fission product radioactivity from containment to the environment. APPLICABLE The limiting DBAs considered relative to containment SAFETY ANALYSES OPERABILITY are the loss of coolant accident (LOCA) and the steam line break (SLB). The DBA LOCA and. SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients. No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed, in regard to containment ESF systems, assuming the loss of one ESF bus, which is the
~ worst case single active failure, resulting in one train of the Containment Spray System, the RHR' System, and the ARS being rendered inoperable (Ref. 2).
The DBA analyses show that the maximum peak containment pressure results from the LOCA analysis, and is calculated to be less than the containment design pressure. The (continued) , lMcGuire Unit 2 B 3.6-41 Supplement 2 l j.
Centainment Spray System B 3.6.6. BASES APPLICABLE maximum peak containment atmosphere' temperature results SAFETY ANALYSES from the SLB analysis and was calculated to be within.the
, (continued) containment environmental qualification temperature during the DBA SLB. The basis of the containment environmental qualification temperature is to ensure the OPERABILITY of safety related equipment inside containment (Ref. 3).
The modeled Containment Spray System actuation from the containment analysis is based on a response time associated with exceeding the containment pressure high-high signal setpoint to achieving full flow through the containment spray nozzles. A delayed response time initiation provides conservative analyses of peak calculated containment temperature and pressure responses. The Containment Spray System total responte time of 45 seconds is composed of signal delay, diesel generator startup, and system startup time. For certain aspects of transient accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the ECCS cooling effectiveness during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For these calculations, the containment backpressure is calculated in O a manner designed to conservatively minimize, rather than maximize, the calculated transient containment pressures in accordance with 10 CFR 50, Appendix K (Ref. 4). Inadvertent actuation is precluded by design features consisting of an additional set of containment pressure sensors which prevents operation when the containment pressure is below the containment pressure control' system permissive. The Containment Spray System satisfies Criterion 3 of 10 CFR 50.36 (Ref. 5). (continued) ll McGuire Unit 2 B 3.6-42 Supplement'2
Centainment Spray System B 3.6.6 BASES (continued) LCO During a DBA, one train of Containment Spray System is required to provide the heat removal capability assumed in
~the safety analyses. To ensure that this requirement is met, two containment spray trains must be OPERABLE with power from two safety related, independent power supplies.
Therefore, in the event of an accident, at least one train operates. Each Containment Spray System includes a spray pump, headers. valves, heat exchangers, nozzles, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon an ESF actuation signal and manually transferring suction to the containment sump. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the Containment Spray System. In MODES 5 and 6, the probability and consequences of these events are reduced because of the pressure and temperature (]j
/
limitations of these MODES. Thus, the Containment Spray System is not required to be OPERABLE in MODE 5 or 6. ACTIONS Ad With one containment spray train inoperable, the affected train must be restored to OPERABLE status within 72 hours. The components in this degraded condition are capable of providing 100's of the heat removal after an accident. The 72 hour Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period.
, (continued) a N-)o McGuire Unit 2 B 3.6-43 Supplement 2 l
1 Containment Spray System B 3.6.6 BASES ACTIONS . B.1 and B.2 (continued) If the affected containment spray train cannot be restored to OPERABLE status within the required Completion Time, the ' plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to-at least M00E.3 within 6_ hours and to MODE 5 within j 84 hours. .The allowed Completion Times are reasonable, ' based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. SURVEILLANCE SR '3.6.6.1 REQUIREMENTS Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. O This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it l involves verification, through a system walkdown or computer status indication, that those valves outside containment and i capable of potentially being mispositioned, are in the ! correct position. j SR 3.6.6.2 Verifying that each containment spray pump's developed head l at the flow test point is greater than or equal to the ! required developed head ensures that spray pump performance ! has not degraded during the cycle. Flow and differential i head are normal tests of centrifugal pump performance g required by Section XI of the ASME Code (Ref. 6). Since.the containment spray pumps cannot.be tested with flow through . the spray headers, they are tested on bypass flow. This l
- test confirms'one point on the pump design curve and is.- H indicative of overall performance. Such inservice !
inspections- confirm component OPERABILITY, trend 1 (continued) l.McGuire. Unit 2 B 3.6-44 Supplement'2 l i
1 l Containment Spray System i B 3.6.6
,g ' BASES L/
SURVEILLANCE SR 3.6.6.2 (continued) REQUIREMENTS' . i performance, and detect incipient failures by indicating abnonnal performance. The Frequency of this SR is in accordance with the Inservice Testing Program. I SR 3.6.6.3 and SR 3.6.6.4 )
~ These SRs require verification that each automatic containment spray valve actuates to its correct position and each containment spray pump starts upon receipt of an actual or simulated Containtent Pressure High-High signal. This Surveillance is not required for valves that are locked, '
sealed, or otherwise secured in the required position under i administrative controls. The 18 month Frequency is based on i the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown these i components usually pass the Surveillances when performed at ! the 18 month Frequency. Therefore, the Frequency was j concluded to be acceptable from a reliability standpoint. 1 O V The surveillance of containment sump isolation valves is l i also required by SR 3.6.6.3. A single surveillance may be used to satisfy both requirements. SR 3.6.6.5 and SR 3.6.6.6 , These SRs require verification that each containment spray , pump discharge valve opens or is prevented from opening and ! each containment spray pump starts or is de-energized and prevented from starting upon receipt of Containment Pressure ; Control System start and terminate signals. The CPCS is described in the Bases for LC0 3.3.2, "ESFAS." The 18 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant
. outage.
1
. ;-$ (continued) tt a !
NL ' LMcGuire Unit. 2 B 3.6-45 Supplement 2 l
Centainment Spray System B 3.6.6 g . BASES U SURVEILLANCE SR 3.6.6.7 REQUIREMENTS (continued) With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. The spray nozzles-can also be periodically tested using a vacuum blower to induce air flow through each nozzle to verify unobstructed flow. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Because of the pr.ssive design of the nozzle, a test at 10 year intervals is-considered adequate to detect obstruction of the spray nozzles.
. REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.
- 2. UFSAR, Section 6.2.
- 3. 10 CFR 50.49.
1
- 4. 10 CFR 50, Appendix K.
- 5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 6. ASME, Boiler and Pressure Vessel Code, Section XI.
i p (continued) O) B 3.6-46 Supplement 2 l McGuire Unit' 2 ' u
Hydrogen R;combin rs B 3.6.7 8 3.6 CONTAINMENT SYSTEMS U B 3.6.7 Hydrogen Recombiners BASES BACKGROUND The function of the hydrogen recombiners is to eliminate the potential breach of containment due to a hydrogen oxygen reaction. Per 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors" (Ref.1), and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2), hydrogen recombiners are required to reduce the hydrogen concentration in the containment following a loss of coolant accident (LOCA). The recombiners accomplish this by recombining hydrogen and oxygen to form water vapor. The vapor remains in containment, thus eliminating any discharge to the environment. The hydrogen recombiners are manually initiated since flammable limits would not be reached until . several days after a Design Basis Accident (DBA). Two 100% capacity independent hy}}