ML20217P847

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Proposed Tech Specs Revising Containment Isolation Valves Completion Times
ML20217P847
Person / Time
Site: San Onofre  
Issue date: 04/06/1998
From:
SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20217P827 List:
References
NUDOCS 9804100209
Download: ML20217P847 (21)


Text

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ATTACHMENT "A" AMENDMENT N0. 127 APPROVED SPECIFICATIONS UNIT 2 l

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9804100209 980406 PDR ADOCK 05000361 P

PDR

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Containment Isolation Valves 3.6.3 ACTIONS.(continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more Sr: tion E.1 Secure the inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> D.1 containment valve (s) in its ESFAS isolationvalve(s) actuated position.

inoperable.

AND

]

E.2 Restore the inoperable Prior to valve (s) to OPERABLE entering MODE 4 status.

from N0DE 5 if MODE 5 entered within 30 days, otherwise within

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30 days F.

One or more Section F.1 Secure the inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> D.2 containment valve (s) in its ESFAS isolationvalve(s) actuated position.

inoperable.

AND F.2 Restore the inoperable Prior to valve (s) to OPERABLE entering MODE 4 status.

from MODE 5.

G.

Required Action and G.1 Be in MODE 3, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

AND G.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> l

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SAN ON0FRE--UNIT 2 3.6-12 Amendment No. 127

t ATTACHMENT "B" AMENDMENT N0. 116 APPROVED SPECIFICATIONS UNIT 3 l

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Containment Isolation Valves 3.6.3 ACTIONS,(ccntinued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more Section E.1 Secure the inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> D.1 containment valve (s) in its ESFAS isolationvalve(s) actuated position.

inoperable.

AND E.2 Restore the inoperable Prior to valve (s) to OPERABLE entering MODE 4 status.

from MODE 5 if MODE 5 entered within 30 days, otherwise within 30 days F.

One or more Section F.1 Secure the inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> D.2 containment valve (s) in its ESFAS isolationvalve(s) actuated position.

inoperable.

AND F.2 Restore the inoperable Prior to valve (s) to OPERABLE entering MODE 4 status.

from MODE 5.

G.

Required Action and G.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

AND G.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SAN ONOFRE--UNIT 3 3.6-12 Amendment No. 116

O ATTACHMENT "C" PROPOSED SPECIFICATIONS UNIT 2 I

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more Section E.1 Secure the inoperable InTacc~ordance D.1 containment valve (s) in its ESFAS with'the '

isolationvalve(s) actuated position.

applicable?LC0 inoperable.

pertaining tof AND thef ESE system in which itiis E.2 Restore the inoperable installed. '~

valve (s) to OPERABLE

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status.

Prior to entering MODE 4 from MODE 5 if MODE 5 entered within 30 days, otherwise within 30 days F.

One or more Section F.1 Secure the inoperable In'accordance D.2 containment valve (s) in its ESFAS withithe isolationvalve(s) actuated position.

applicable ^LCO inoperable.

pertaini_ng,to' AND the ESF system in whichiit.is F

F.2 Restore the inoperable installed. ~

valve (s) to OPERABLE

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status.

Prior to entering MODE 4 from MODE 5.

G.

Required Action and G.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

AND G.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

.nc SAN ON0FRE--UNIT 2 3.6-12 Amendment No. 4N

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ATTACHMENT "D" PROPOSED SPECIFICATIONS UNIT 3 I

Containment Isolation Valves-3.6.3 ACTIONS.(continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more Section E.1 Secure the inoperable Infaccordance D.1 containment valve (s) in its ESFAS with:the~

isolationvalve(s) actuated position.

applic'able1LC0 inoperable.

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pertaining:to AND the:ESF: system

, l in whichritiis E.2 Restore the inoperable installed?'~

valve (s) to OPERABLE status.

Prior to entering MODE 4 from MODE 5 if MODE b entered within 30 days, otherwise within 30 days l

F.

One or more Section F.1 Secure the inoperable In~accordance D.2 containment valve (s) in its ESFAS with the' isolation valve (s) actuated position.

applicable'LCO inoperable.

pertainingito" AND the ESF system 3

in which-.it:is F.2 Restore the inoperable installed.

valve (s) to OPERABLE

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status.

Prior to entering MODE 4 from MODE 5.

G.

Required Action and G.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated C woletion Time not met. '

AND G.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> l

SAN ON0FRE--UNIT 3 3.6-12 Amendment No. 4 M 1

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ATTACHMENT "E" UNITS 2 AND 3 REVISED BASES B.3.6.3 (FORINFORMATIONONLY) j

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Containment Isolation Valves B 3.6.3 BASF5 ACTIONS D.I. D.2. and 0.3 (continued)

Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR more often.

1 Therefore, a Frequency of once per 184 days was chosen and has been shown to be acceptable based on operating experience.

E1. E.2. F71. and F~.'2 These Actions require certain containment isolation valves to be secured in their ESFAS actuated position and restore the inoperable valve to OPERABLE status.

The1completiorEtime"(CT)Tfor SectionLD;1Fand D;2 valves is c

based on'.restoringithe:ESFjSystem to OPERABLE.! status; "

Therefore, the appropriate. completion time is'basedionLthe specific ESF System Requirements

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The second" completion times in different for th-Sections D21 and D.27 valves are^differentibased on the results of^

specific risk evaluatibnffor' valves that may be secured open.fThe second comp 1.etionitimesf areiforTrestoring complete 1(open:and'close)operabilityofthe; valves:

Secti orf D.1=and. D;2 Jval vesTmay' be; pl aced L i nto the" requi red 7

action: condition Lto allow; periodic! testing. and testi_ng f

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following;maintenange.

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G.1 and G.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODF ;r 4.Sich the LC0 does not apply.

To achieve this status, r.be alant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ai.6 to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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)

SAN ON0FRE--UNIT 2 B 3.6-22 Amendment No. 127 05/31/97

  • 1*'

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.1 i

REQUIREMENTS Each 42 inch 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 opening of a containment purge valve.. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4.

A containment purge 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 bv 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. 3), related to containment purge valve use during unit operations.

This SR is not required to be met while in Condition D of this LCO.

This is reasonable since the penetration flow path would be isolated.

SR 3.6.3.2 This SR ensures that the minipurge valves are closed as required or, if open, open for an allowable reason.

The SR is not required to be met wnen the purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillar.ces that require the valves to be open. The minipurge valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to De 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.

SR 3.6.3 3 This SR requires verification that each containment isolation manual valve and blind flange located outside containment and required to be closed during accident (continued)

SAN ON0FRE--UNIT 2 B 3.6-23 Amendment No. 127 05/31/97

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Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.3 (continued)

REQUIREMENTS (continued) conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. Thin SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those f

valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for 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. Valves that are open under administrative controls are not required to meet the SR during the time the valves are open.

The first Note applier 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 valves,

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once they have been verified to be in the proper position, J

is small.

The second note specifies that SR 3.0.4 is not applicable.

SR 3.6.3.4 This SR requires verification that each containment isolation manual valve and blind flange located inside containment 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 the containment boundary is within design limits.

For 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 valves and flanges are operated under administrative controls and the probability of their misalignment is low.

Valves that are open under administrative controls are not required to meet the SR during the time that they are open.

(continued)

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SAN ON0FRE--UNIT 2 B 3 6-24 Amer.dment No. 127 05/31/97

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-Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.4 (continued)

REQUIREMENTS (continued)

The.first 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 valves, once the3 have been verified to be in their proper position, is small The second note specifies that SR 3.0.4 is not applicable.

SR 3.6.3.5 Verifying that the isolation time of each power operated and automatic 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 anal sis. The

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isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J (Ref. 5), 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 to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref.3).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a (contir:aed)

SAN ON0FRE--UNIT 2 B 3.6-25 Amendment No. 127 05/31/97

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.6 (continued)

' REQUIREMENTS (continued) valve that has not been opened).

Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated again,t the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage-rate to verify containment OPERABILITY.

SR 3.6.3.7 The containmeit isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes. Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures each automatic l

containment isolation valve will actuate to its isolation position on an actuation signal.

The 24 month Frequency was l

developed considering it is prudent that this SR be l

performed only during a unit cutage, sir:ce isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Opetating experience has shown that these components usually pass this SR when performed on the 24 month Frequency. Therefore, the Frcquency was concluded to be acceptable from a reliability standpoint.

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(continued) i SAN ON0FRE--UNIT 2 8 3.6-26 Amendment No. 127 05/31/97

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  • Containment Isolation Valves B 3.6.3 BASES REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J.

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l SAN ON0FRE--UNIT 2 B 3.6-26a Amendment No. 127 05/31/97

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Containment Isolation Valves B 3.6.3 BASES ~

ACTIONS D.I. D.2. and D.3 (continued)

Since more reliance is placed on a single valve.while in this Condition, it is prudent to perform the SR more ofter.

Therefore, a frequency of once per 184 days was chosen and has been shown to be acceptable based on operating experience.

Eil. E!2. F01, and F02 These Actions require _certain containment isolation valves to be secured in their ESFAS actuated position and restore the inoperable valve to OPERABLE status. The ~ completion timet(CT) [for;Section"D.1Fand D;2; val'esTis/bssed on' v

restoring?theLESFjSystem to'0PERABLE? status.> EThereforesthe sppropriate"complet. ion 3iyefisibasedfon5theispecificiESF" ~

System Requirements g The secondicompletion times in diff=nt-for the-Sections D21 and D.2 valves are"differentLbased on the results of'

- specificTfisk evaluations'foFValves that may be~ secured open MThelsecondf compl etion? timesare7forl restoring complete;(openjand!close)foperabilitylofthevalyesy f

Secti onJ D ~.1Tand ; D;2l val ves'ima91be'; pl aced li ntif the" requi red

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actionEconditionito -allow periodic 3 estingianditesting' t

following.mainteancef G.1 and G.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 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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)

' SAN ON0FRE--UNIT 3 8 3.6-22 Amendment No. 116

?

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each 42 inch 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 opening of a containment purge valve. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close dudng a LOCA in time to limit offsite doses.

Therefore,.,ese valves are required to be in the sealed closed pos! son during MODES 1, 2, 3, and 4.

A containment purge valve that is sealed closed must have motive power to the valve operator removed. This can be

.I 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. 3), related to containment purge valve use during unit operations. 1his SR is not required to be met while in Condition D of this LCO.

This is reasonable since the penetration flow path would be isolated.

I 1

SR 3.6.3.2 This SR ensures that the minipurge valves are closed as required or, if open, open for an allowabie reason. The-SR is not required to be met when the purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The minipurge 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.

SR 3.6.3.3 This SR requires verification that each containment i

isolation manual valve and blind flange located outside containment and required to be closed during accident (continued)

. SAN ONCFRE--UNIT 3 B 3.6-23 Amend. ment No. 116

G.'

i Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.3 (continued)

REQUIREMENTS (continued) conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. This SR does not require any testing or valve manipulation.

Rather, it involves verification,. through a system walkdown, that those valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for 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.

Valves that are open under administrative controls are not required to meet the SR during the time the valves are open.

The first 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 valves, once they have been verified to be in the proper position, is small. The second note specifies that SR 3.0.4 is not applicable.

SR 3.6.3.4 This SR requires verification that each containment isolation manual valve and blind flange located inside containment 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 the containment boundary is within design limits. For valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is approptiate, since these valves and flanges are operated under administrative controls and the probability of their misalignment is low. Valves that are open under administrative controls are not required to meet the SR during the time that they are open.

(continued)

SAN ON0FRE--UNIT 3 8 3.6-24 Amendment No. 116

e-Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.4 (continued)

REQUIREMENTS (continued)

The first 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 valves, once they have been verified to be in their proper position, is small The second note specifies that SR 3.0.4 is not applicable.

SR 3.6.3.5 Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is required to demonstrate OPERAB:LITY. The isolation time i

test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J (Ref. 5), 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 to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref.3).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a (continued)

SAN ONOFRE--UNIT 3 B 3.6-25 Amendment No. 116

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Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.6 (continued)

REQUIREMENTS (continued) valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

SR 3.6.3.7 The containment isolation valves covered by this SR are required to be' demonstrated OPERABLE at the indicated frequency'.This SR is modified by two notes. Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 l

Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures each automatic containment isolation valve 'will actuate to its isolation position on an actuation signal. The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

i (continued)

SAN ON0FRE--UNIT 3-B 3.6-26 Amendment No. 116

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Conce';nment Isolation Valves

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B 3.6.3 BASES-REFERENCES.

1.

SONGS Units 2 and 3 UFSAR,'Section 6.2.

.2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

i 4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J.

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-SAN ON0FRE--UNIT'~3 B 3.6-26a Amendment No. 116 05/31/97 i