ML20235G495
| ML20235G495 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/17/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235G470 | List: |
| References | |
| NUDOCS 8709300071 | |
| Download: ML20235G495 (59) | |
Text
{{#Wiki_filter:- - _ _ _ - _ - _ _ _ __ _ _ _ - .- ENCLOSURE 1 PROPOSED YECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 i (TVA-SQN-TS-87-33) PROPOSED AMENDMENT TO LIMITING CONDITION FOR OPERATION (LCO) 3.6.1.2,
" CONTAINMENT SYSTEMS, CONTAINMENT LEAKAGE" LIST OF AFFECTED PAGES Unit 1 1-1 3/4 6-2 1-2 3/4 6-4 1-3 3/4 6-5 l 1-4 3/4 6-6 1-5 1-6 1-6a Unit 2 1-1 3/4 6-2 1-2 3/4 6-4 l
1-3 3/4 6-5 1-4 3/4 6-6 1-5 1-6 , 1-7 I l l I I i I 8709300071 070917 7 i PDR ADOCK 05000 P
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DEFINITION BYPASS LEAKAGE PATH 1.3 A BYPASS LEAKAGE PATH is a potential path for leakage to escape.from
- both the primary containment and annulus pressure boundary. Only one type of BYPASS LEAKAGE PATH is recognized:
- a. BYPASS LEAKAGE PATHS TO THE AUKILIARY BUILDING are those paths.
that would potentially allow leakage from the primary containment to circumvent the annulus secondary containment enclosure and escape directly to the Auxiliary Building secondary containment enclosure.
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%Q 1.0 DEFINITIONS )
DEFINED TERMS The defined terms of this section appear in capitalized type and are applicaole ' throughout these Tecnnical Specifications. ACTION 1.1 ACTION shhll be that part of a 5;.. edification which prescribes remedial measures required under designated conditions. AXIAL FLUX DIFFERENCE 1.2 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals
.. between the top and bottom halves of a two section excore neutron detector. pu
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4MS*k CHANNEL CALIBRATION g s/ "drA72.s 4 WNE' , 1.f A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the g cnannel output such that it responds with the necessary range and acc.: racy to
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- known values of the parameter which the channel' monitors. The CHANNEL CALIBRA-TION shall encompass the entire channel including the sensor ano alarm and/or 4,g trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Tne CHANNEL CALIBRATION may be performed by any series of secuential, overlapping or total channel steps such that the entire cnannel is calibrated.
CHANNEL CHECK
.s 1./ A CHANNEL CHECX shall be the qualitative assessment of channel behavior -
during operation by observation. This determination shall incluce, wnere possible, comparison of the channel indication anc/or status with other incica-tions and/or status cerived from incepenoent instrument enannels measuring tne same parameter. CHANNEL FUNCTIONAL TEST e 1.f A CitANNEL FUNCTIONAL TEST snali be: g
'a . Analog channels - the injecticn of a simulated signal into the -
cnannel as close to the sensor as practicatie to verify GPEF.AE.LITY including alar: and/or trip functions.
- b. Eistable cnannels - the injection of a simulated signal into tne
- -- .wnur to verify OPERABILITY-including ala :t and/or trip functions. - -
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SEQUOYAH - UNIT 1 1-1 ~ n,.- . ;.- . - . n (kh
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DEFINITIONS 4
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CONTAINMENT INTEGRITY Y
-1.g CONTAINMENT INTEGRITY shall exist when:
h a. All 3
- arepenetrations either: required to be closed during accident conditions 1 1)
!. Canable of being closed by an OPERABLE containment automatic isolation valve system, or
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1 4 2)" n Closed by manual valves, blind flanges, or deactivated automatic
-] valves secured in their closed positions, except as provided in
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Table 3.6-2 of Specification 3.5.3. b. All equipment hatches are closed and sealed. c. Each air lock is OPERABLE pursuant to Specification 3.6.1.3, d. The containment leakage rates are within the limits of Specificati<.n 3.6.1.2, and e.
.The sealing mechansim associated with each penetration (e.g.,
welds, bellows, or 0 rings) is OPERABLE.
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CONTROLLED LEAKAGE 'l .?b c l i f CONTROLLED coolant pump seals. LEAKAGE shall be that seal water ficw supplied to the CORE ALTERATION 1.8' within the vessel..the reactor pressure vessel with the vessel head re ,
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movement of a component to a safe conservative position. Suspensio . DOSE ECUIVALENT I-131 sc 1.# DOS! gram) wnich EQUIVALENT alone would produce I-131 the same shall thyroicbeC0se thatasconcentration the cuantity anc l of isotopic mixture of I-!31. 1-132, I-133, 1-132, and :-135 ectually present. The thyroid dose conversion facto *5 , listec enc TestinReactor Table III Sites." of TID-14844, " Calculation of Distance Factors wer for Poused fo l i
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,9 l DEFINITIONS E - AVERAGE'0 DISINTEGRATION ENERGY of -
1.30[ E shall be the. average (weighted in proportion to.the concentration of each radionuclides in the. reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, l other than iodines, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant. ENGINEERED SAFETY FEATURE RESP 0 NEE TIME
/i' 1.yf The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interva'l g from when the monitored parameter exceeds its ESF actuation setpoint at the channel. sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach'their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable'.
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FREOUENCY NOTATION u FM; 1.12' The FREQUENCY NOTATION specified for the performance of Surveillance Requi,rements shall correspond to the intervals defined in Table 1.2. l R16 GASEOUS RADWASTE TREATMENT SYSTEM
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1.11 A GASEOUS RADWASTE TREATMENT SYSTEM is any system designed and installed
. to reduce radioactive gaseous effluents by collecting primary coolant system g
offgases from the primary system and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment. IDENTIFIED LEAKAGE
/s 134' IDENTIFIED LEAKAGE shall be:
a'. l Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured and conducted
- 3 to a sump or collecting tank, or
- b. Leakage into the containment atmospnere from sources that are botn specifically located and known either not to interfere with the operation of leakage detection .cystems or not to be PRESSURE BOUNDARY -
LEAKAGE, or e
- c. Reactor coolant system leakage through a steam generator to the seconcary system.
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cf am/ J Nchicd SpectUda19dns fjee. DEFINITIONS ( OFFSITE DOSE CALCULATION MANUAL (ODCM)
/7 1.16 The OFFSITE DOSE CALCULATION MANUAL shall contain the current methodology and parameters used in the calculation of offsite doses due to radioactive {
gaseous and liquid effluents, in the calculation of gaseous and liquid effluent F46 monitoring alarm / trip setpoints, and in the conduct of the environmental radio-logical monitoring program. OPERABLE OPERABILITY
/8 1.)6 A system, subsystem, train, or component or device shall be OPERABLE or have l OPERABILITY when it is capable of performing its specified function (s), and when i all necessary attendant instrumentation, controls, a normal and an emergency electrical power source, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s).
. OPERATIONAL MODE - MODE t.9 1.M An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive I combination of core reactivity condition, power level and average reactor (
coolant temperature specified in Table 1.1. PHYSICS TESTS"
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- 1. ) 8' PHYSICS TESTS shall be those tests performed to measure the fundamental (v.
nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.5o, or 3) otherwise approved by the Commission. PRESSURE BOUNDARY LEAKAGE 2/ 1.J1 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body,' pipe wall or vessel wall. PROCESS CONTROL PROGRAM (PCP) 22
- 1. M The FROCE55 CONTROL PROGRAM shall contain the current formula, sampling, analysis, tests, and determinations to be made to ensure that the processing and R46 packaging of solid radioactive wastss based on demonstrated processing of actual or simulated we. solid wastes will be accomplished in sucn a way as to assure comoliance with 10 CFR Part 20, 10 CFR Part 71, and federal and state regula-tions and other requirements governing the disposal of radioactive wastes.
PURGE - PURGING 23 1JT PURGE or PURGING is the controlled process of discharging air or gas i from a confinement to maintain temperature, pressure, humidity, concentration j or other operating condition, in sucn a manner that replacement air or gas is -- - -- I required to purify the confinemen+
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5 DEFINITIONS SOLIDIFICATION
.41 1.,28 SOLIDIFICATION shall be the conversion of wet radioactive wastes into a form that meets shipping and burial ground requirements. R46 SOURCECHEg u .-
1.,59 A SOURCE CHECX shall be the qualitative assessment of channel resnonse when the channel sensor is exposed to a radioactive source. STAGGERED TEST BASIS E:J 1.,30 A STAGGERED TEST BASIS shall consist of: a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals, b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval. THERMAL POWER
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.l.31 reactor THERMAL coolam.,POWER shall be the total reactor core heat transfer rate to the
_ UNIDENTIFIED LEAKAGE g.; 1.32 -UNIDENTIFIED LEAXAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE. 4 . VENTILATION EXHAUST TREATMENT SYSTEM S7 1.31 A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed l to reduce gaseous radiciodine or radioactive caterial in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or particulate from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any offect on ncble gas effluents). Engineered R46 Safety. Feature (ES?) atmospheric cleanup systems are no: considered to be VENTILATIGH EXHAUST TREATMENT SYSTE.9 components. VEN ING 25 . 1.3 ' VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not inoly a VENTING process. . __
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SEQUOYAH - UNIT 1 1-6 Amendment No. 42 ,7 gg33i.
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DEFINITIONS
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1.35 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee (see Figure 5.1-1). UNRESTRICTED AREA 1.36 An UNRESTRICTED AREA shall be any area, at or beyond the site boundary to which access is not controlled by the licensee for purposes' of protection of 1 individuals from exposure to radiation and radioactive materials or any area R4r: within the site boundary used for residential quarters or' industrial, commer-cial, institut'ional, an11or recreational purposes. MEMBER (S) 0F THE PUBLIC <
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1.3T MEMBERS OF THE PUBLIC shall include all individuals who are not occupa-tionally associated with the plant. This category shall include non-employees of the licensee who are permitted to use purtions of the site for recreational, p occupational, or other purposes not associated with plant functions. This category does not. include non-employees such as vending machine servicemen or I postmen who, as part of their formal job function, occasionally enter an area that is controlled by the licensee for purposes of protection of individuals J
]from exposure to radiation and radioactive materials.
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4 ADDITIONS TO ACTION STATEMENT FOR LCO 3.6.1.2 ITEM TEXT 1 (c) with the combined bypass leakage rate exceeding 0.25 La for BYPASS L2AKAGE PATHS TO THE AUXILIARY BUILDING, 2 the combined bypass leakage rate from BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING to less than or equal to 0.25 L a-l l I l
CONTAINMENT SYSTEMS CONTAINWNT LE AKAGE /
. LIMIi1NG CON 0! TION FOR OPERATION 3.6.1.2 Containment leakage rates shall be limited to.:
- a. An overall integrated leakage, rate of less than or equal to L,,
0.25 percent by weignt of the containment air per 24 hours at P , 12 psig,
- b. A combined leakage rate of less than or equal to 0.60 L, for all penetrations and valves subject to Type B and C tests, when pressurized to P .
a
- c. A combined bypass leakage rate of less than or equal to 0.25 L for a .
, all penetrations identified in Table 3.6-1 as secondary containment
'p bypass leakage-paths when pressuri:ed to P .
a s' E W M. L LE A< ALI P A rcts 7 0 Ts2 A 0 x a t.,z y E uc N c., - ADDLICABILITY: MODES 1, 2, 3 and 4 ACTION: t with either (a) the measured overall integrated containment leakage rate exceeding 0.75 L,, or 'b) with the measured comDined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L,, or M . serf e r,4 u ith- the-comb i ned . bypa s s lea kage--ra t e-exc eed i ng--0,25-4 r restore the a ( Mdd, /;u.5 overall integrated leakage rate to less than or equal to 0.75 L,, the combined rf N/79/ leakage rate for all penetrations and valves subject to Type E and C tests to J/cehyrn# less than or eQ'al to 0.60 L . and_tte_.cc=binec-cypa s s te a ka g e-rate--to- 1+ n-4- 265 -tsa r--o r-ec ua Ltr a
%L.,. p-io- to in:-easing the Rea: tor Ceciant Syste-p te pe ature above 200*F.
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CONTAINMENT SYSTEMS SURVEILLANCE REOUIRJYENTS (Continued)
- d. Type B and C tests shall be concucted with gas at Pa (12 psig) at l
intervals no greater nan 21 montns except for tests involving-i
- 1. Air locks,
- 2. Penetrations using continuous leakage monitoring systems, and
- 3. Valves pressurized witn fluid from a seal system.
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- e. Tne comoined bypass leakage rate'shall be determinec~to be less than or epual to 0.25 L, by a;olicaole Type B and C tests at least or.ce per 24 months except for penetrations wnich are not individually testable; penetrations not individually testable shall be determined i to have no detectable leakage wnen tested with soao bubbles while the containment is pressurized to Pa (12 psig) during each Type A ,
test.
- f. Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3. ,
- g. Leakage from isolation valves that are sealed with fluid from a seal system may be excludec, subject to the provisions of Appencix J, Section III.C.3, when determining the combined leakage rate provided the seal system and valves are pressurized to at least 1.10 P, (12.2 psig) and the seal system capacity is adecuate to maintain system pressure.(or fluid head for tne containment spray system valves at penetrations 48 A and 28 .R) for a: leas. 30 cays.
- h. Type B tests for penetrations employing a continu0us leaAage ,
monitoring syster snall :e connuc ed at ;, ('I psi;) at intervals no i greater than once per 3 years. '
- i. All test leakage rates shall ce calculated using ceserved ca a converted to a0 solute values. Erro* analyses snall ce cerformed to select a :alantec intec. rated leakat.e measurement s.yster
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, DEFINITION BYPASS LEAK'UE PATH l
1.3 A BYPASS LEAKAGE PATH is a potential path for leakage to escape from both the primary containment and annulus pressure boundary. Only one type of BYPASS LEAKAGE PATH is recognized: ! i a. ! BY" ASS LEAKAGE PATHS TO THE AUXILIARY BUILDING are those paths th;.c would potentially allow leakage from the primary ' containment to circumvent the annulus secondary containment enclosure and escape directly to the auxiliary building l secondary containment enclosure. l 5 4
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- 1.0 DEFINITIONS 4 l
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, DEF*NED TERHS l
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications. 1 i ACTION 1.1 ACTION shall be that part of a Specification which prescribes remedial measures required under designated conditions. 4 AXIAL FLUX DIFFERENCE 1.2 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals between the top and bottom halves of a two section 6xcore neutron detectors. EN 5 a c t -> l
! DEF+ noo CHANNEL CALIBRATION '
oc ' BY9%S 4 u mG g. 1.3 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the lj M . he " channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALI- l BRATION shall encompass the entira channel including the' sensor and alarm
- and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any serier of sequential, overlapping
[.N or total channel steps such that the entire channel is calibrated. N-i
, CHANNEL CHECK 4
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- 1. 4' A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where ~
possible, comparison of the channel indication and/or status with other s I indications and/or status derived from independent instrument channels measuring the same parameter. l l l
,' CHANNEL FUNCTIONAL TEST '
1.5' A CHANNEL FUNCTIONAL TEST shall be:
- a. Analog channels - the injection of a simulated signal'into the 1
channel as close to the sensor as pr::cticable to verify OPERABILITY
.; including alarm and/or trip functions. -
. b. Bistable chanhels - the injection of a simulated signal into the
; sensor to verify OPERABILITY including alarm and/or trip functions.
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j . DEFINITIONS 3 CONTAINMENT INTEGRITY , 7 1.E CONTAINMENT INTEGRITY shall exist when: '
- a. All penetrations required to be closed during accident conditions are either; i 1) Capable of being closed by an OPERA 8LE coritainment automatic isolation valve system, or
- 2) Closed by manual valves, blind flanges, er deactivated auto-matic valves secured in their closed positions, except as provided in Table 3.6-2 of Specification 3.6.3. .
- b. All equipment hatches are closed and sealed,
- c. Each air lock is CPERABLE pursuant to Specification 3.6.l.3,
- d. The containment leakage rates are within the limits of Specification ~'
3.6.1.2, and e. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE. C0'NTROLLEO LEAKAGE B 1.7 CONTROLLED LEAXAGE shall be that seal water flow supplied to the reactor ~ coolant pump seals. j
~
CORE ALTERATION .
't 1.E 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, ?reclude completion of movement of a component to a safe conservative position.
00SE EQUIVALENT I-131
/d 1.F DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcurie /
gram) which alone would produce the same thyroid dose as the qt.antity and iso-topic mixture of I-131, I-132, I-133 I-134, and I-135 actually present. The ' thyroid dose conversion f actors used for tnis calculation shall be those j listec in Table III of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites." i j 4 .:. p 9 J
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- ' C.-79,;.,; 3 i.g, l SEQUOYAH - UNIT 2 1-2 u ,
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rp.. E - AVERAGE DISINTEGRATION ENERGY l // g 1.10' I shall be the average (weighted in proportion to the concentration of l i 3 4 each radionuclides in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, ' other than iodines, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant. l , ENGINEERED SAFETY FEATURE RESPONSE TIME
/d ~
h , l 1.11' The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the l I channel sensor until the ESF equipment is capable of performing its safety ' i function (i.e. , the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. - -- FRE00ENCY NOTATION
/d 1.12 The FREQUENCY NOTATION specified for the performance of Surveillance .ec Requirements shall correspond to the intervals defined in Table 1.2.
4 GASECUS RADWASTE TREATMENT SYSTEM !
/4 g i 1.23 A GASE0f!S RADWASTE TREATMENT SYSTEM is any system designed and installed 5 !
to reduce radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing for delay or holdup for the purpose of ' educing the total radioactivity prior to release to the environment. IDENTIFIED LEAKAGE
, /$
1.14' IDENTIFIED LEAKAGE shall be:
- a. Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pumo seal or valve packing leaks that are captured and conducted to a sump or collecting tank, .or i
- b. Leakage into the containment atmosphere from sources that are both .
specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or
- c. Reactor coolant system leakage through a steam generator to the secondary system. ~ -
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' DEFINITIONS '
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' OFFSITE DOSE CALCULATION MANUAL _
t/ 1.15 and parameters used in the calculation of offsite doses du) ' eous and liquid effluents and in the calculation of gaseous and liquid effluent i monitoring alarm / trip setpoints and in the conduct of the radiological environ-mental monitoring program. lT l I OPERABLE - OPERABILITY
/b 1.16 A system, subsystem, train, or- component or device shall be OPERABLE or have OPERAILITY when it is capable of performing its specified function (s), h and when all necessary attendant instrumentation, controls, a normal and an emercancy electrical power source, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, com-ponent or device to perform its function (s) are also capable of performing their related support function (s).
OPERATIONAL MODE - MODE it 1.17 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1. l PHYSICS TESTS
- 3 (
1.18 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) h described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or 3) otherwise approved by the Commission. PRESSURE BOUNDARY LEAKAGE 2/ 1.19 PRESSURE BOUNDARY LEAK %GE shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component h body, pipe wall or vessel wall. PROCESS CONTROL PROGRAM (PCP) 1.20 The PROCESS CONTROL PROGRAM shall contain the current formula sampling, analysis tests, and determinations to be made to ensure that the processing 7 and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to cssure compliance with 10 CFR Part 20, 10 CFR Part 71, and federal and state regulations and other requirements governing the disposal of radioactive wastes. l . i.m 11. January 15,1986 SEQUOYAH - UNIT 2 1-4 - Amendment No. [34 y. l -.
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I l _._ DEFINITIONS PURGE - PURGING
.M 1 21 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration h
or other operating condition, in such a manner that replacement air or gas is required to purify the confinement. QUADRANT POWER TILT RATIO EY 1 22' QUADRANT POWER TILT RATIO shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector cali-h brated outputs,'or the ratio of the maximum lower excore detector calibrated l output to the average of the lower excore detector calibrated outputs, which- ! ever is greater. With one excore detector inoperable, the remaining three, detectors shall be used for computing the average. RATED THERMAL POWER z.i 1.23 RATED THERMAL POWER shall be a total reactor core heat transfer rate to ' the reactor coolant of 3411 MWt. REACTOR TRIP SYSTEM RESPONSE TIME ~'
- s. . g 1.24 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from g when the monitored parameter exceeds its trip setpoint at the channel sensor until loss of stationary gripper coil voltage.
REPORTABLE EVENT 27 1.25' A REPORTABLE EVENT shall be any of those conditions specified in Section h 'R2 8 50.73 to 10 CFR Part 50. SHIELD BUILDING INTEGRITY l') SHIELD BUILDING INTEGRITY shall exist when:
- a. The door in each access opening is closed except when the access opening is being used for normal transit entry and exit. .
- b. The emergency gas treatment system is OPERABLE.
- c. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.
November 23, 1984 ,[h~Qh$ SEQUOYAH - UNIT 2 1-5 AmendmentNo.^28][. yip
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SHUT 00WN MARGIN \ l w 1.27 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which 3 the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the e, ingle rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn. SOLIDIFICATION 3/ . l 1.28 form that SOLIDIFICATION meets shipping shall be the and burial conversion ground of wet radioactive wastes into a hg34 requirements. l SOURCE CHECK 32 1.28 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. h STAGGERED TEST BASIS
.2d 1 I
129 A STAGGERED TEST BASIS shall consist of: g
- a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing t..e specified test interval into n
-c:;ual subintervals,
- b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.
THERMAL POWER S9 yg 1.31 reactor THERMAL coolant. POWER shall be the total reactor core heat transfer rate to the g i UNIDENTIFIED LEAKAGE JS 1.32 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE 3 or CONTROLLED LEAKAGE. _ 5/73d/W c/es /?Ybbr? O f "/. M A [ 3 0 8 /C 7"[ D AREA " hCr>7 ,Ck?ff l'l of ardf 2 fn& pies / 5,0cenicsherAs /7ere. January 14, 1986 ,9 ',yM SEQUOYAH - UNIT 2 1 , AmendmentNo.'3'jf.
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l l . . DEFfN1TIONS l
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) VENTILATION EXHAUST TREATMENT SYSTEM 31 i 1.33' A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and g installed to reduce gaseous radiciodine or radioactive material in particulate g i form in effluents by passing ventilation or vent exhaust gases through charcoal { adsorbers and/or HEPA filters for the purpose of removing iodines or partic-ulates from the gaseous exhaust stream prior to the release to the environment l
. (such a system is not considered to have any effect on noble gas effluents). {
Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered Ii to be VENTILATION EXHAUST TREATMENT SYSTEM components. VENTING 33 I 1.34' sg VENTING is the controlled process of discharging air or gas from a g l confinement to maintain temperature, pressure, humidity, concentration or other operating provided condition, or required in such a manner that replacement air or gas is-not during VENTING. imply a VENTING process. Vent, used in system names, does not
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SITE BOUNDARY
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_. leased, or otherwise controlled by the licensee (see figure 5.1-1). ,t D?cw ib phrys /-6, j i _ UNRESTRICTED AREA Moret dAer o'eSw'7k ef '4W/OfMW/ED MM44f'? ,
._-- T 1.36 An UNRESTRICTED AREA shall be any area, at or beyond the site boundary to which access is not c.ontrolled by the licensee for purposes of protection of 1
individuals from exposure to radiation and radioactive materials or any area j within the site boundary used for residential quarters or industrial, commer- ~ cial, institutional, and/or recreational purposes. e a (7mce o pu,pe /-t',m.w/ Mm desda s ' We'.rkr zu MrwM7edamm f MEMBERS OF THE PUBLIC
/k 1.37 MEMBERS OF THE PUBLIC shall include all individuals who are not occupa-tionally associated with the plant. This category shall include non employees of the licensee who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with plant functions. This category does not include non employees such as vending machine servicemen or postmen who, as part of their formal job function, occasionally enter an area that is controlled by the licensee for purposes of protection of individ-uals from exposure to radiation and radioactive materials.
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ADDITIONS TO ACTION STATEMENT FOR LCO 3.6.1.2 ITEM TEXT 1 (c) with the combined bypass leakage rate exceeding 0.25 L a for BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING, 2 the combined bypass leakage rate from BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING to less than or equal to
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CONTAINMENT SYSTEMS . (s. j CONTAINMENT LEAKAGE i i t.IMITING CONDITION FOR OPERATION _ l l
- 3. 6.1. 2 Containment leakage rates shall be limi.ted to: l l
- a. An overall integrated leakage rate of less than or equal to L,, 0.25 I percent by weight of the containment air per 24 hours at P ' 12 a
psig.
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b. A combined leakage rate of less than or equal to 0.60 L, for all penetrations and valves subject to Type B and C tests, when pressurized to P . i 3
. ~.
- c. A combined bypass leakage rate of less than or equal to 0.25 L I" a l all penetrations identified in Table 3.6-1 as secondary containment '
bypass-leakage-paths when pressurized to P,. ((,
\ 13WASS LE A K Ace Turns rd Tu ri AuxiL A Rx Botuotu c, APPLICABILITY: MODES 1, 2, 3 and 4.
ACTION: With either (a) the measure'd overall integrated containment leakage rate exceeding 0.75 La , r (b) wich the measured combined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L,, or
+ fc-)-*Rh-the-combined-bypass-leakagewate--exceeding 4-254,, restore the overall integrated leakage rate to less than or equal to 0.75 L , and the a
combined leakage rate for all penetrations and valves subject to Type B and C tests to less than or equal to 0.60 Lf, and-the--combined-bypass-leakage-rate- % , l
-to-less-than-or-equal-to-Or25-L, prior to increasing the Reactor Coolant System temperature above 200 F.
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SURVEILLANCE REQUIREMENTS (Continued)
- 3. Valves pressurized witn fluid from a seal system.
te +he audlia e w 6. id mg s
- e. Tnecamcinedbypassleakageratebhallbedeterminedtobelesstnan of equal to 0.25 L aby acplicable Type 8 and C tests at least once
[ per 24 months except for pene,trations which are not individually testable; penetrations not individually testacle shall be determined to haye no detectacle leakage wnen tested with soap butbles while the containment is pressurized to Pa, 12 psig, during each Type A test,
- f. Air locks snail be tested and demonstrated CPERABLE per Surveillance Requirement 4.6.1.3.
- g. Leakage from isolation valves that are sealed with fluid frcm a seal system may be excluded, subject to the provisions of Appendix J, Section III.C,3, when determining the combined leakage rate provided the seal system and valves are pressurized to at least 1.10 P,, 13.2 ,
psig, and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system valves at 3 penetrations 48A and 488) for at least 30 days. l l
- h. Type B tests for penetrations employing a continuous 1.akage monitoring system shall be conducted at3P ,12 psig, c.t intervals no greater than once per 3 years. )
- 1. All test leakage rates shall be calculated using observed data converted to absolute values. Error analyses shall be performed to select a balanced integrated leakage measurement system. l
- j. The provisions of Specification 4.0.2 are not applicable.
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a l l ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION (TS) CitANCE SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA SQN TS 87-33) { DESCRIPTION AND JUSTIFICATION FOR PROPOSED AMENDMENT TO LIMITING CONDITION FOR OPERATION (LCO) 3.6 1.2,
" CONTAINMENT SYSTEMS, CONTAINMENT LEAKAGE"
. ENCLOSURE 2 DESCRIPTION OP CHANGE The proposed amendment would effect the following changes:
A definition of " BYPASS LEAKAGE PATH TO THE AUXILIARY BUILDING" is added to Section 1.0, " Definitions," of the SQN technical specifications. The definitions are reordered so that they will be listed alphabetically. The text of Limiting Sondition for Operation (LCO) 3.6.1.2 pf the associated ACTION statement, and of Surveillance Requireceti (SR) 4.6.1.2 item e is amended to replace " BYPASS LEAKAGE PATHS" witn BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING. Table 3.6-1 is amended to reflect the definition of BYPASS LEAKAGE PATHS TO THE AUKILIARY BUILDING and the current plant configuration. Change the designation of the hydrogen purge penetration from "X-400" to "X-40D." (Note--The underline was added for emphasis.) REASONS FOR CHANGES The reasons for the changes that would be affected by the proposed amendment are: Reduce or eliminate confusion over what is meant by BYPASS LEAKAGE PATHS by stating a concise definition of BYPASS LEAKAGE PATH TO THE AUXILIARY BUILDING. Incorporate the definition of BYPASS LEAKAGE PATH TO THE AUXILIARY BUILDING into the text of LCO 3.6.1.2, of the applicable ACTION statement, and of SR 4.6.1.2 item e. List those penetrations in table 3.6-1 that satisfy the definition of j BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING. Correct a typographical error in the penetration designation given for the hydrogen purge penetration. Relist definitions alphabetically in section 1.0 of the SQN technical specifications so they can be found more quickly. JUSTIFICATION FOR CHANCES The justification for the changes that would be affected by the proposed amendment follows. ! 1 I . _ _ _ _ _ _ _ _ _ _ _ _ _
} l .- l
-Summary The secondary containment is provided to mitigate the postulated consequences of hypothetical accidents by enveloping the primary containment and collecting and treating the fission product leakage from primary containment.
The secondary containment consists of the annular volume (annulus) around the primary containment and the Auxiliary Building secondary containment enclosure boundary. During a postulated Design Basis Accident (DBA), leakage from the primary containment to the annulus may occur. This leakage would be treated ; by the emergency gas treatment system (EGTS). 1 It is also possible that, because of piping and valve arrangements, some leakage may bypass the annulus. This leakage from the primary containment that circumvents the annulus pressure boundary may escape directly into either the Auxiliary Building or the environment. Bypass leakage to the Auxiliary Building in defined as that leakage from primary containment that would possibly circumvent the annulus and escape to the Auxiliary Building during a postulated DBA. This leakage will be treated by the Auxiliary Building Gas Treatment System (ABGTS). l Bypass leakage to the environment is defined as that J eakage from primary l containment that would possibly circumvent both the annulus and the Auxiliary i Building, allowing the communication of fission products from containment with
- the environment without being first filtered by either the ECTS or ABGTS. The l design of SQN precludes any bypass leakage to the environment.
Background
l l It is possible that not all primary containment leakage may be collected for l the following reason: Leakage from the primary containment can bypass the secondary i containment through containment penetrations, pipings, and seals that do not terminate in the secondary containment, Method of Determining Leakage Paths The SQN containment design was reviewed to identify and evaluate bypass leakage paths both to the Auxiliary Building and to the environment. The evaluation of bypass leakage involved the following: Identification of bypass leakage paths. Determination of leakage rates. penetrations through both the primary and secondary containment may include a number of barriers to leakage such as isolation valves, seals, gaskets, and welded joints. While each barrier aids in the reduction of leakage, it does not necessarily eliminate leakage. Therefore, in identifying potential leakage paths, each path was considered, together with the capability to test it for leakage in a manner consistent with the containment leakage tests as required by 10 CFR part 50. Appendix J. l \ l l
j 1 Penetrations that present potential bypass leakage paths were evaluated for design features that would prevent such leakage. The following design features were considered adequate for that purpose: Closed systems inside containment. .These systems have the following requirements: , The system does not communicate with the primary containment atmosphere.
- The system has a safety classification of TVA class C.
The system is rated to withstand external pressures and temperature to at least the levels of the containment design levels.
- The system is environmentally qualified to accident transients and the resulting environment.
- The system is protected against possible missiles, pipe whip, and jets.
Closed systems outside containment. These systems have the following requirements: The system does not communicate with the atmosphere outside of containment. The system has a safety classification of TVA class C.
- The internal design pressure and temperature limits of the system are at least equal to containment design pressure and '
temperature limits. The system is protected against possible missiles, pipe whip, i and jets.
- Fluid seal systems in piping. Credit for fluid seals preventing !
leakage was taken provided the following criteria were satisfied:
- The fluid inventory was sufficient to ensure the seal for 30 .
l days.
- The pressure of the seal system fluid of the valve was at 1 cast 13.2 psig at all times.
. The pressure and inventory criteria for the fluid seal system did not consider a single failure criteria.
1 l e
. i Gas-filled lines with appropriately located valves and in-line !
leakage nipples. These lines, which pass through the annulus and run ' to the Auxiliary Building, had the following design features: A third isolation valve was located outside the annulus region or Auxiliary Building. One or more in-line leakoff nipples were located in the annulus region between the second and third isolation valves. If a line is isolated by two additionally closed valves in addition to the containment isolation barriers, this line is considered to not be a potential bypass leakage path to the environment. One or more of the preceding design features in a potential bypass leakage path precludes such leakage to the environment. Paths that penetrate pritsry containment and that do not terminate within the secondary containment were considered potential bypass leakage paths around i the leakage collection and filtration systems of the secondary containment. l Isolation barriers in these paths that were evaluated for leakage include: I 1 Isolation valves in piping that penetrates both the primary and l secondary containment barriers. . Seals and gaskets on penetrations that pass through both the primary and secondary containment barriers. Welded joints on penetrations (guard pipes) that pass through both the primary and secondary barriers. In addition to identifying leakage paths, the ability to leak rate test the paths was also evaluated. Evaluation Summaries i
)
Penetrations in containment were evaluated for potential leakage paths to the Auxiliary Building and for potential leakage paths to the environment. Those penetrations that clearly terminated in the Auxiliary Building were identified, and no additional evaluation was pe. formed for bypass leakage to the environment. For those penetrations that could potentially provide a leakage path to the environment, an evaluation of the line was performed to assess which, if any, of the design features identified previously were incorporated into the line to preclude leakage to the environment. Summaries of those evaluations follow. A. Penetrations X-1. -25B. -26A. -27A. -27B. -54 -79A._-79B. -85B. -87B.
-87D. -88. -92A, -92B, -97 -99 -100. -102. -104 -111. -112. -113. -117, i
-118. X-120E through -12AE. X-126E through -129E. X-131E through -154E. l X-156E through -161E. and X-163E through -170E l
The lines for the above penetrations terminate in the annulus region. l Thus, these penetrations are neither bypass leakage paths to the environment nor bypass leakage paths to the Auxiliary Building. t i _ - - - - - - - - - \
4
-S-B. P_ penetrations X-2A, ~2B. -3. -23. -25A. -25D, -27C. -84A -85A. -91. -93.
-94A -94B. -94C. -95A -95B. -95C. ~96C. -98. -101. -103. -106 and -116A The linen for these penetrations terminate in the Auxiliary Building.
Thus, these penetrations are not bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building. C. penetrations X-4 -5. -6 -7 t_-9A. -9B. -10A. -10B. -11. and 80 The lines passing through these penetrations are for the containment heating, ventilating, and air-conditioning (HVAC) system. Containment irolation is provided for in these lines by an air-operated valve both in inboard and outboard of containment. Bypass leakage to the environment is prevented by locating a second air-operated valve in either the annulus or the Auxiliary Building outboard of the outbcard containment isolation valye and the installation of in-line leakoff nipples between the two outboard valves in the annulus. Thus, these lines are neither bypass leakage paths to the environment nor to the Auxiliary Building. D. Penetrations X-8 -18. -28. -31. -36. -37. -38 -39C. -39D. -40C. -55.
-84B. -84C. -84D. -85C. -85D. -86D. -87A. -87C. -89. -96A. -96B. -105.
-116B. -1160. -116D -119 -120. -125E. -130E, -155E. and 162E These penetrations are spa"e penetrations having welded endcaps. Thus, these penetrations are neither bypass leakage paths to the environment nor are they bypass leakage paths to the Auxiliary Building. j E. Penetrations X-12A 7 -12B. -12C, and -12D l
The steam generator main feedwater lines run through these penetrations, j The steam generator secondary side is a closed system inside containment, 1 Thus, lines that connect to the steam generator secondary side are also closed systems inside containment. In addition, the secondary side of the steam generators is kept at a higher pressure than the reactor coolant system (RCS) primary side almost immediately following initiation of a DBA. It follows that any leakage that may occur would be directed inward to the containment from the steam generator secondary side through the RCS. Thus, these lines are neither a bypass leakage path to the environment nor to the Auxiliary Building. F. Penetrations X-13A. -13B. -13C. and -13D I The steam generator main steam lines run through these penetrations. As was found fur the main feedwater lines, lines that connect to the steam generator secondary side are closed systems inside containment. Also, the steam generator secondary side is maintained at a higher pressure than the RCS primary side almost immediately following initiation of a DBA. It follows that any leakage that may occur would be directed inward to the primary containment from the steam generator secondary side through the RCS. ThJs, these lines are neither a bypass leakage path to the environment nor to the Auxiliary Building.
. C. Penetrations X-15. -16. -43A. -43B -43C. -43D. and -44 )
i These penetrations are associated with the chemical and volume control ) system (CVCS) and a'e c for the letdown line (X-15), normal charging line l (X-16), the reactor coolant pump (RCP) seal injection lines (X-43A, -43B,
-43C, and -43D), Snd the RCP seal water return line (X-44).
The letdown line (X-15) is isolated on a phase f. containment isolation signal by three inboard air-operated flow control valves (FCVs), a pressure relief valve, and one outboard air-operated FCV. There is a seal formed by a 23-foot head of water on the outboard side of the inboard FCVs. The water seal alone is not sufficient te preclude 1cakage through the line at the value of pasesi (Pa) for analyses of record. However, : considering both the water seal and the two additional isolation valves in l the letdown line (FCV-62-69 and FCV-62-70) located inside containment, this path is evaluated as precluding leakage to the environment. ; FCV-62-69 and FCV-62-70 are air operated, and upon receipt of a low ! pressurizer level signal, these -raives automatically isolate. Thus, this line is not a bypass leakage path to the environment but is a potential i bypass leakage path to the Auxiliary Building. The RCP seal water injection lines (X-43A, -43B, -43C, -43D) are designed , to be in service postaccident, supplying seal water to the RCPs. The ! discharge pressure of the charging pumpe, which feed these lines, is in 1 excess of 1.1 times the calculated peak containment internal pressure related to the DBA, or 1.1 Pa, thereby sealing this line to leakage paths from containment. Thus, the lines through these penetrations are neither bypass leakage paths to the environment nor bypass leakage paths to the Auxiliary Building. In addition to a check valve inside containment and a FCV outside containment, the normal charging line (X-16) has at least one additional ' check valve inside containment and one additional FCV outside j containment. Also, the charging pumps will continue to operate for 30 days following a postulated DBA with a discharge pressure in excess of 1.1 pa. Thus, the line through this penetration is neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. The RCP seal water return line (X-44) has a check valve and a motor-operated valve (MOV) inside containment and an MOV outside containment. Any leakage that may occur through these valves would be returned to the suction side of the charging pumps. Thus, the line through this penetration is not a bypass leakage path to the environment but is a potential bypass leakago path to the Auxiliary Building. H. Penetrations X-14A. -14B 2 -14C. and -14D The steam generator blowdown lines run through these penetrations. As was l found for the main feedwater lines, lines that connect to the steam generator secondary side are also closed systems inside containment. l l l
Also, the stcam generator secondary side is maintained at a higher pressure than the RCS primary side almost immediately following initiation of a DBA. It follows that any leakage that may occur would be directed inward to the primary containment from the steam generator secondary side through the RCS. Thus, these lines are neither a bypass leakage path to the environment nor to the Auxiliary Building I. penetrations X-17. -20A. and -20B These lines running through these penetration are the residual heat removal (RHR) pump discharge for train A (X.20B), train B (X-20A), and the RHR return (X-17). Outside containment, th" Rha is a closed system. Also, any lines running from the closed system to the refueling water storage tank (RWST)~are sealed by a water 108 of 15.6 psig and are isolated by two additional valves. Furthermore, the penetrations are subjected to a water seal at a pressure in excess of 1.1 Pa from the operation of the RHR pumps. Thus, these lines are neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. J. penetrations X-19A and -19B The lines running through these penetrations run to the RHR sump. Shortly following initiation of a D3A, these lines are submerged under coolant that has escaped from the RCS, Also, these lines have a water seal inside containment. These two features prevent passing of containment atmosphere through these lines postaccident. Thus, these lines are neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. K. Penetrations X-21. -22. -32, and -33 The lines running through these penetrations are the safety injection (SI) pump discharge to the RCS hot legs for train A (X-32) and train B (X-21), l the SI pump dischtrgo (X-33), and the boron injection tank (BIT) charging pump discharge (X-22). Outside containment, these lines run to closed systems. Also, any lines running from the closed system to the RWST for suction are sealed by a water leg with a minimum pressure of 15.6 psig and are isolated by redundant valves. Finally, the penetrations themselves have a water seal from the SI pumps that has a pressure in excess of 1.1 Pa. These linen are neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. L. penetration X-24 The line running through this penetration is the SI relief valve discharge. This line runs to a closed system outside containment--either the RHR system, SI system (SIS), or containment spray system. Also, any lines running off the closed systems run to the RWST, are sealed with a water lag having a minimum prescure of 15.6 psig, and are isolated by
._____ _ _______ a
two additional valves. Finally, the pressure in the closed loop is greater than 1.1 pa. Thus, this line is neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. M. penetrations X-25C. -26C. -27D. -85A, -86B. and -86C The lines through these penetrations are for the reactor vessel level indication system. These lines are water filled and have a sensor bellows check valve to separate the reactor coolant from the sense line, a check valve, and hydraulic isolators (high displacement differential pressure switches) as floating check valves. The hydraulic isolators also employ a doubic bellows design such that, in the unlikely event that a break or leak should occur, the shaf t travels to close the line. The shaft movement is fesigned to isolate the high-pressure side of the broken or leaking line. Thus, these lines are neither bypass leakage paths to the environment nor bypass leakage paths to the Auxiliary Building. N. penetrations X-26B. -34 -40D. -76, and -90 These penetrations are for lines from the compressed air system. The compressed air system consists of the control air system, penetrations X-26B, -34, and -90, and the service air system, penetrations X-40D and
-76. Compressed air for these systems is supplied by one of four redundant air compressors that maintains the system pressure between 97 and 105 psig, The lines running through penetrations X-26B, -34, and -90 are for the )
control air system. Each line through the three penetrations has an 1 inboard check valve and an outboard air-operated FCV in parallel with a normally closed manual valve. As stated above, these lines are normally ' pressurized to levels well in excess of 1.1 pa. It is also noted that a large amount of air-operated equipment does not have automatic isolation of its compressed air supply. The lines associated with this equipment , make up a large volume. In the unlikely event that all four air compressors would be lost or disabled, this large unisolated volume of the ( compressed air system would nake it essentially impossible to repressurize I the system from containment leakage. Thus, these lines are evaluated as not being bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building. The lines running through penetrations X-40D and -76 are for the service air system. The line tunning through penetration X-40D has a check valve inside containment and a blind flange sealed with a double 0-ring gasket l outside containment in the Auxiliary Building. Thus, the line through this penetration is not a bypass leakage path to the environment but is a potential bypass leakage path to the Auxiliary Building. l The line through penetration X-76 is isolated by two locked-closed manual valves, one inside containment and one outside containment. In addition, a third manual valve will be administrative 1y closed; and a vent valve between the outtoard isolation valve and the third valve will be ' administratively locked open. This will provide a leakoff to the
l Auxiliary Building from both primary containment and the compressed air l supply. Thus, the line through this penetration is not a bypass leakage path to the environment but is a potential bypass leakage path to the Auxiliary Building. O. Penetrations X-29. -35. -50A. -50B. -52 and -53 The lines running through these penetrations are for the conponent cooling system (CCS). Specifically, the lines run from the RCP coolers (X-29), the excess letdown heat exchanger (X-35 and -53), the RCP thermal barrier return (X-50A), the RCP thermal barrier supply (X-50A), and the RCP oil coolers (X-52). Except for the excess letdown heat exchangers, the CCS is a closed system outside containment. There is one possible vent path, a vent from the system surge tank to the Auxiliary Building. Thus, the i lines running through these penetrations are not bypass leakage paths to i the environment but are potential bypass leakage paths to the Auxilkary Building, ] j The excess letdown heat exchangers (penetrations X-35 and -53) are closed ) systems inside containment. As such, the lines running through these j penetrations are neither bypass leakage paths to the environment nor j bypass leakage paths to the Auxiliary Building. l P. Penetration X-30 The line running through this penetration is a test line that extends to all four SIS accumulators. The penetration is isolated by one inboard air-operated FCV and two air-operated FCVs (one for each of two branch lines). One branch line outboard of containment has a possible flow path to the waste disposal system (WDS). Any leakage from the WDS will be i i directed into the Auxiliary Building. The other branch line runs to the ) S1 pump discharge; the SI pump will supply a pressure in excess of 1.1 Pa to the valve for 30 days following a postulated DBA, thus precluding bypass leakage through this valve. Thus, this line is not a bypass leakage path to the environment but is a potential bypass leakage path to the Auxiliary Building. Q. Penetrations X-39A. -39B. -41. -45. -46 and -81 These penetrations are associated with the WDS and are for the nitrogen supply to the accumulators (X-39A), nitrogen supply to the pressure relief tank (X- 39B), floor cump pump discharge (X-41), reactor coolant drain tank (RCDT) and pressurizer relief tank (PRT) to vent header (X-45), RCDT pump discharge (X-46), and RCDT to gas analyzer (X-81). The nitrogen supply to the accumulators (X-39A) has a check valve inside containment and an air-operated FCV outside containment that receives a j phase A containment isolation signal. Once isolated, the nitrogen supply ' system maintains a static pressure on the FCV that exceeds 1.1 Pa. Thus, this line is neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. l
l l _10-1 The nitrogen supply to the PRT (X-39B) has the same isolation scheme as ' that given for penetration X-39A. However, a pressure control valve immediately outboard of the outboard containment isolation valve for penetration X-39B can regulate the nitrogen pressure to as low as 6.5 psig. Thus, the line through this penetration is not considered a bypass leakage path to the environment but is a potential bypass leakage path to the Auxiliary Building. All of the liquid and gaseous waste containment penetrations (X-41, -45,
-46, and -81) are isolated on receipt of a pnase A containment isolation signal. The outboard containment isolation valves for these penetrations are air-operated diaphragm valves. Leskage through these penetrations is routed to either liquid holding tanks or gaseous holding tanks that are designed to hold and treat the leakage before either reuse or discharge. I Thus, these lines are not bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building.
R. penetrations X-40A and -40B The lines running through these penetrations are auxiliary feedwater lines. As was found for the main feedwriter lines, in that the steam generator secondary side is a closed system inside containment, lines that connect to the steam generator secondary side are also closed systems inside containment. Also, the steam generator secondary side is maintained at a higher pressure than the RCS primary side almost immediately following initiation of a DBA. It follows that any leakage that may occur would be directed inward to the primary containment from the steam generator secondary side through the RCS. Thus, these lines ar( neither bypass leakage paths to the environment nor bypass leakage paths j to the Auxiliary Building. S. Penetration X-42 The primary waterline runs througty this penetration and has a check valve ) inboard of containment and an air-3perated FCV outboard of containment. l The FCV receives a phase A containment isolation signal. The primary ) water makeup pumps do not receive - stop signal, except on a low primary i water storage tank level, thus mai:.taining a water seal pressure in excess l of 1.1 Pa on the FCV. This will preclude leakage to the environment and , leakage to the Auxiliary Building. Thus, this line is neither a bypass 1eakage path to the environment not tha Auxiliary Building. l T. penetrations X-47A. -47B. -114. and -115 The lines passing through these penetrations are glycol lines running to I and from the ice condenser. Specifically, the lines are to and from the I glycol air coolers, penetration X-47A and X-47B respectively, and to and ] from the glycol floor coolers, penetrations X-114 and -115, respectively. !
)
_11_ These four lines exit containment into the Auxiliary Building, pass through the Auxiliary Building roof, run for approximately 10 feet on the Auxiliary Building roof, and then reenter the Auxiliary Building. These lines run to a point in the Auxiliary Building adjacent to the additional equipment building, pass through the unit 2 side of the Auxiliary Building, run for approximately 10 feet on the additional equipment building roof, and then enter the additional equipment building. These lines are not possible bypass leakage paths to the environment for the following reasons:
+
The glycol lines are designed, f abricated, and constructed to the requirements identified in American National Standards Institute (ANSI) B31.5. This code is as stringent as ANSI B31.1 or TVA class C.
+
The glycol lines will not lose their pressure boundary integrity because of missiles, pipe whip, or jet impingement where they are routed external to the Auxiliary Building. Additionally, a j LOCA with a concurrent seismic event is a low probability event, t so the glycol lines do not need to be seismically qualified. An analysis providing justification for this argument is provided in attachment 1. Therefore, the glycol lines, external to the Auxiliary Building, meet the technical requirements for a " closed" system, so these lines do not represent a potential bypass leakage path to the environment. However, these lines are potential bypass leakage paths to the Auxiliary Building. U. Penetrations X-48A and -48B The lines running through these penetrations are for the containment spery system. Outside containment, these lines form closed systems. Lines
- running from the closed systems, which run to the RWST, are sealed by a water leg with a pressure of 15.6 psig and are isolated by valves. A water seal is maintained inboard of containment with a head pressure in excess of 1.1 Pa, and there is a closed system outside of containment.
Thus, the lines through these penetrations are neither bypass leakage paths to the environment nor bypass leakage paths to the Auxiliary Building. V. Penetrations X-49A and -49B The lines from these two penetrations run to the RHR spray headers inside containment. Outside containment, these lines form closed systems. Lines running from the closed systems, which run to the RWST, are scaled by a water leg with a pressure of 15.6 psig and are isolated by two additional valves. Furthermore, the penetrations have a water seal placed on them in excess of 1.1 Pa by the operation of the Rl!R pumps. Thus, these lines are neither bypass leakage paths to the environment nor bypass leakage paths l to the Auxiliary Building. l l
l i W.- Penetrations X-51 and -78 The lines through these penetrations are for the fire protection system. A liquid seal is. maintained on the lines entering or exiting the Auxiliary ] Building by header pressure supplied by either two 10,000-gallon head tanks located on top of the Auxiliary Building or by one of four fire pumps. Each fire pump is rated for 1,500-gal / min, flow at 400-foot head ; d
.and satisfies the requirements for American Society of Mechanical Engineers (ASME) section III, class 3, seismic catego'ry 1. Thus, these 4 lines are not bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building because of possible containment atmosphere leakage from the outboard motor-operated '
containment isolation valve stem. X. Penetrations -56. -57. -58. -59. -60. -61. -62. -63. -68. -69. -70. -71.
-72. -73. -74, and -75 l
The lines through these penetrations are for the essential raw cooling water (ERCW) system. Primary containment isolation of the ERCW supply lines is provided for by an inboard check valve and outboard MOV. Primary containment isolation of the ERCW discharge lines is provided for by an inboard MOV in parallel with a bypass check valve and an outboard MOV. All MOVs receive a phase B containment isolation signal to close. In the unlikely event that a train of ERCW should fail, a water seal having a 29.0-foot waterhead will be provided on the outboard containment isolation valves. Any leakage of the water seal will be made up by the discharge of the operable train of ERCW flowing back into the piping of the inoperable train. Thus, these lines are not bypass leakage paths to -) the environment. However, because of a number of test vents that are l ne'Lther capped nor tested, they could possibly provide a leakage path for j the Auxiliary Building. TVA will consider these lines a bypass leakage path to the Auxiliary Building. Y. Penetrations X-64. -65. -66, and -67 The lines running through these penetrations are waterlines to and from the containment air chillers. These lines are part of a closed system ) l outside containment. Thus, these lines are not bypass leakage paths to ' the environment but are potential bypass leakage paths to the Auxiliary Building. Z. Penetration X-77 ' The line through this penetration is for the demineralized water system. This penetration has a check valve inside containment and two local manual containment isolation valves outside containment. The two outboard local manual valvec are locked closed during normal operation, modes 1 through 4. A vent valve between the two outboard local manual valves will be locked open to ensure leakage is to the Auxiliary Building and not the environment. 'Thus, the line through this penetration is not a bypass leakage path to the environment but is a potential bypass leakage path to 1 the Auxiliary Building. I 1 l
~13-AA. Penetrations X-82 and -83 The lines running through these penetrations are to the refueling cavity pump suction (X-82) and discharge (X-83). These lines branch beyond the outboard containment isolation in each line. Each line is either isolated by a water les seal in lines running to the RWST or by running to the WDS. Any leakage from the WDS will be to the Auxiliary Building. '
Thus, these lines are not bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building. BB. Penetration X-107 The line running through this penetration is the RHR supply line. Outside containment, this line runs to a closed system. Also, any lines running from the closed system to the RWST for suction are sealed by a water leg with a minimum pressure of 15.6 psig and are isolated by two additional valves. A water leg exists inside containment from the reactor where this line connects to the penetration of the line through containment. This water leg will prevent leakage of containment atmosphere through this line. Thus, this line is neither a bypass leakage path to the environment nor a bypass leakage path to the Auxiliary Building. CC. Penetrations X-108 and -109 These two lines, one per penetration, are upper head injection (UHI) system injection lines. These lines are scaled on the outboard side by water with a nitrogen cover gas that has been pressurized in excess of 1.1 Pa. Thus, these two lines are not bypass leakage paths to the environment but are potential bypass leakage paths to the Auxiliary Building. There is additionally one test line running off each of the two main lines. These test lines connect to other test and vent lines that are either isolated by two additional normally closed valves or lines that j empty into the floor and equipment drain sump of the WDS. This sump vents to the Auxiliary Building. Thus, these two test lines are not ! bypass leakage paths to the environment but are potential bypass leakage j J paths to the Auxiliary Building. DD. Penetration X-110 The line that runs through this penetration is the UHI system valve test line. This line has all branches either isolated by two additional closed valves outboard of the containment isolation valves or by one additional valve and relief to the floor and equipment drain sump of the WDS. Any WDS leakage will be into the Auxiliary Building. Thus, this line is nct a leakage path to the environment but is a potential leakage path to the Auxiliary Building. l l i I
- - --- 9
-14_ ')
1 Evaluation of Capability to Leak Rate Test
.All leakage paths that were identified as potential bypass leakage paths to the Auxiliary Building were evaluated for ability to perform leakage rate testing.
The leakage rate testing will be consistent with the requirements of 10 CFR 50, Appendix J, type B or C leak tests for valves and other testable penetrations. For welded joints, an acceptable alternate for local leakage rate testing was taken to be a soap bubble test of the welds performed concurrently with the primary containment integrated leak rate test as identified in 10 CFR 50, Appendix J, type A leak testing requirements.
' Leakage detected by such soap bubble testing of welds would result in the repair of the affected weld (s) before termination of the primary containment integrated leak rate test.
l l Leakage rate limits for bypass leakage to the Auxiliary Building will be as defined in the technical specifications. Correct Typographical Errors The correct designation of the hydrogen putte penetration is "X-40D." Table 3.6-1 currently lists that penetration as "X-400." The proposed amendment would ccerect the designation given for the hydrogen purge penetration in table 3.(.-1 from "X-4,00" to "X-40D." Reorder Definitions In addition to the definition that would be added to section 1.0 of the SQN technical specifications by the proposed amendment, several other definitions have been added by previous amendments. Those definitions have typically been added to the end of the definition list without regard to alphabetical ordering. Organizing the definitions in alphabetical order will allow them to be found more quickly. The proposed amendment would restructure the list of definitions given in section 1.0 of the SQN technical specifications so that the definitions appear in alphabetical order. < l t l t i 1
l
- SGw- 5Gs ?- cGy e Sheet 2 of M4+If l . Ccmputed CAJ Date 4104&
Checked KTy m DAte 4 2t- S+ I. INTRODUCTION: DME was recuested to perform a review of bypass leakage caths. Criteria were develeced cased on the recommendations of the Branch Technical Position on bypass leakage. The criteria which were established, to determine if a system represented a potential leakage path, have been included as Attachment A. The g1/cci lines do not comply with the criteria. Therefore. NEB has been recuested te develco the justification for requesting a specific enemption, from the criteria. for the glycol lines. II. ASSUMPTIONS: Ncne
~ III.
REFERENCES:
- 1. Secuevah Nuclear Plant Technical Specifications Unite 1 !< 2 '
O. Secuoyah Nuclear Pl ant Final Safety Analysis Repcrt
?. Safety Evaluation Repert NUREG-OO11 4 Saf ety Evalautien Report Supplements Numbers 1-5
- 5. Standard Review Plan NUREG-OSOO
- 6. Branch Technical Positien CSB 6-3. " Determination of Bypass Leakage Paths in Dual Containment Plants"
- 7. SON-DC-V-2.15 " Design Criteri a - Containment Isolation System"
- 5. SON-DC-V-5.0. " Design Criteria - The Classification cf Piping, Pumes. Valves. and Vessels" SON-DC-V-7.2, " Design Criteria - The Classification of Heating, Ventilating, and Air-Cend.itiening Systems"
- 10. SON-DC-V-27.1. " Design Criteria - Ice Ccndensor System"
- 11. ANSI B31.1 - 1 67. " Power Piping"
- 12. ANSI E!1.5 - loS3. " Refrigeration Piping"
- 12. 47WS14 Series - Fl ew Di agram Ice Condensor System
- 14. 47W462 Series - Mechanical Ice Cendensor System
- 15. 47EM462 - Bill of Materi al s Ice Ccndenser System
- 16. NRC Generic Letter 57-02. " Verification of Seismic Adecuacy of Mechanical and Electrical Equipment in Operating Reacters.
Unresolved Safety Issue (USI) A-46" (A02 570414 031)
- 17. OIR NEBS 7170. "Manimum Leakage Directly f rom Primar y Cont ai nment to the Environment" (B45 970512 256)
, Affac kewi i -
%<d 5 J,'&,p ot TVA 10697 (DNE 646) QA Record D 'NE CALCULATIONS i
TITt.E E ali< alien +4 +xe ice condeasor S n<al-1.liaes Je+eemine if *e g reeresed PLANT / UNIT a p.hnVial b ypass \tAkAy p%h 40 ike enVirDOMint ,5QN l y 7,
' PREPARING ORGANIZATION DNE.-N66 EY PAM NOUNS leakcge (Consult
, corMminced RIMSiS014T DESCRIPTORS(LIST)hak onf k,irn 15R ANCH/ PROJECT lDE NTIFIE RS Eactitime these calculations are issued, preparers rnust ensure that the original (RO) RIMS accession number is hiled sn.
NN"DM* b Rev ~ (for RIMS' use) RIMS accession number ao 870804A0008 B 2s 87 072 2 802 APPLICABLE DESIGN DOCUMENT (S) 3,e u .a u +. IMiORMATION OniLY l B25 870905 805
"- I g,5ECTION(S) UNID SYSTEM (S) =NE0RMAT10LONLY -
- 9. o ei -
Revision 0 R1 R2 R3 Safety related? ECN No. (or indicate Not Applicable) Yes O No 7 (Q/ A N/A Statement of Problem Pr p red. The ice c.onclinsor glycol llnes pcss
- M *U d/E T-i id -{ Lro >$b Ivofh ha pr[ma r and5ccendety
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n Appdvo eW. n ulm 1Vd-.- Date ' W 7-z2-87r m, List all pages added y by this revision. $/td // cl/2 E Z List all pages deleted pkf by this revision. h[A Ul byListthisall pages changed revision. %/ 5,f jg Abstract These calculations contain an unverified assumpti s) that must be verified later. Yes O No hggf intifin hrensk b5 ffl r" Oh fM MA4 O A "he 6CC t.pnMf n so r }lytok !lf\f5. 3tgg j [n, g g(o nd (4ch(M b b6 Cf tbIlA e5 % bed M . preckucI t "lkrir king Ch%'i[ie) g ,, 3 p kA.i rdraw ph . b<d ea he evalub r<se,sle')[E,u (ln,s do rd represed
. p a:J hej t<d.y A % e ene - ~ J .
l I l k O M,c,oe.im and sio,e caicuiai .n. in rim 3 Servae cenire. __ M,crovaim and desirov. O b Microfilm anct return calculations to- (/, A, Mg 4 l 7, g4taDNAli # # ' cc: RIMS, SL ' # E____.____._ _3_ $ _ N~y6 A C K ha a #^~ n f.D.Brg5,b5C-C,3MJ
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Sheet 3 o N Ytiz ) Ccmputed OAH Date b ro-M l Checked Kr/Dw Date 7-u-84 } IV. ANALYSIS: The ice cendenser glycc1 system picing utilices fcur penetrations (X-47A. -47B. -114, L -115) to pass thrcugh the primary containment. Each penetration is isolated by a TVA Class B inbcard and outboard containment isclatien valve and consists cf TVA Cl ass B piping between each velve. Outside containment, the glycel lines enit to the reef cf the Auniliary Building and run accronimately 19 feet before thev re-enter the AB; the ' lines cass threugh the AB. enit the building a second time. and run for apprenimately 12 feet ever the roof of the Additional Ecuipment Building; and then the glycol lines enter the Additional Equipment Building. These lines are presently designed to TVA Class N requirements (i . e. . no seismic qual i f i cati on ) . The glycci lines routed inside the containment are TVA Class M (i . e. . limited seismic qualification). i Ref erence 7 Section 7.11. " Bypass Leakage Paths." defines a bypass l 1eakage path to the environment as a route where radionuclides released I durin; en accident could be discharged to the environment without being filtered by either the emergency gas treatment system (EGTS) er the auniliary building gas treatment system (AESTE). Presently, SON's dose calculations assume no direct leakage to the environment as stated in Reference !. Table 15.2. Attachment A lists the criteria developed by TVA to assess each
, .cntainment penetration to determine if that path represented a potential bypass leakage path to the environment. The glycc1 piping inside and cutside containment did not comply with the piping classification specifi ed in the criteria f er a " closed" system (Class B and Class C rescecti vel y) , it was conservatively assumed that the piping would net maintain its pressure boundary integrity. Assuming worst case locations for each of the two breaks (i.e., cne break 1ccatien cutside the muniliary building and the second inside containment), a potential bypass l eakege path enicts tc the environment. This analysis is intende.d to document f er the specific case of the glycel lines that this ratienale is overly conservative. That is, based on the technical . justification presented, the system as presently designed is adequate to ensure no bypass leakage to the environment.
Fcr the glycol'~1ines outside containment to be censidered a "c1csed" system, they must meet TVA Class C requirements. This implies these lines are Seismic Categcry I, per Reference 8. NUREG-1211, " Regulatory Analysis for Resolution of Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants," documents the LOCA and the seismic event do not occur simultaneously, and the seismic event does not cause the LOCA. Additionally, the probability of a safe shutdown earthcuake (EEE) occurring within 100 days following the LOCA has been determined to be 2.79E-6 per year (B45 960114 276). Thus. the LOCA and the seismic event can be considered as independent events which do not occur simultaneously, and it is possible to develop a position that the TVA Class N piping from a seismic standpoint is acceptable.
i 500-5452-03$8 { Sheet 4 of MYSIL Comcuted CAA Date ~4 to -M Checked Kr/ > Date _
- D se As stated in Attachment A, the glycol lines must be designed for the manimum containment pressure and temperature (conservatively assumed to be i 12'psig and 250*F). The glycol piping is designed for 150 psig and -20*F in acccrdance with the requirements identified in Reference 12.
Considering that the glycol lines have been hydrostatically tested to system design pressure (per ANSI B 1.5), it is clear that the 12 psig containment presstve will net cause these lines to lose their pressure : boundary integrity. Additionally, the ice condensor glycol system has been operational fer ten years at a system operating pressure exceeding 12 , psig. The cede allowable stress of 15,000 psit will not be enceeded by the thermal stress induced by the temperature of the lines going from -20 F to !!O'F. Thus, the possibility of these lines losing their pressure boundary integrity due to direct environmental effects does not exist. Environmental effects such as radiation and humidity are not addressed herein, for their ef f ects should be inconsequential. Addi t i on al l y, the glycol lines are designed, fabricated, and constructed in accordance with the requirements of TVA Class N identified in Reference 12. ANSI B31.5, specifically addresses Brittle fracture, stress intensification f actors, flexibility stress, and places more stringent requirements on determination of minimum wall thickness; therefore, cur present as-constructed configuration equals or enceeds the requirement of TVA Class C. Per Reference 8, TVA Class C invokes the requirements identified in Reference 11. Therefore. should these lines be cecifieo as TVA Class C ecuivalent, this would actually represent a
.owngrading of the system, particularly in the areas of design and materials. for any future modifications being made. (Attachment B)
Last, the issue of missiles, pipe wrip, and Jets must be addertssed. For the glycol lines enternal to the ABECE, the configuration is such that they will not experience any adverse affects. The only credible nissiles are ternado missiles, and a tornado is not postulated concurrently with a LOCA. These lines are not located near any high energy lines, thus precluding a possible loss of pressure boundary integrity due to pipe whip and jet impingement. Therefore, the lines enternal to the AB tctally satisfies this requirement.
- ASTM A!00 for temperatures of 650*F or less.
l l
Sog-SQs t- co4 6 Sheet 5o[$N$$tt Comcuted CM Date U 20-0 Checked Kf/r#w Late 3 D - e4 l i V.
SUMMARY
First, the CIS conferms to the requirement of 10CFR50 Appendix A i General Design Criteria. Second, the Icss of pressure boundary cutside containment due to a ceismic event concurrent with the LOCA is an ove-ly conservative and unrealistic assumptien: recent NRC documentation supports this argument. Third, the glycol lines outside containment meets or i enceeds (in the areas of design, fabrication, and construction) the ' l requirement specified by TVA Class C. Fourth, the post-LOCA environment l will not lead to the loss of pressure boundary integrity of the piping outside containment, for the pressure and temperature induced stresses do not enceed code a11cwables. Lastly, the glycc1 lines cutside centainmment , are net likely to lose their pressure boundary integrity due to missiles, i pipe whip, or jet impingement. VI. CONCLUSIONS: This evaluation of the glycci lines assesses the likelihood cf their becoming a potential bypass leakage path to the environment. Based on the evaluation, the glycol lines satisfy the intent of the requirements for a closed" tystem cutside containment. There is not sufficient
, justification to mandate any modifications to SON's existing containment isolation system. Presently, SON is not committed to Reference 6 which would require this system tc be " closed" (i . e, TVA Class B cr C). Any modifications to move in this direction could be construed as a tacit commitment tc this Branch Technical Pesi t i on .
The containment isolation system meets the requirements of 10CFR50 Appen di x A General Design Criteria and SER Section 6.0.4 states: "We have reviewed the containment isolation system with respect to General Design Critoria 54, 55, 56, and 57 ... and on the basis of conformance with these criteria, we conclude that the design of the containment isolation system is accectable." The lines enternal lose their presgure 5c to the auniliary building A,seismicIcadingkUS$$k"ugdaryintegrity, far theyneed will not not be assumedanto[I'* ng enperience Sight induce a failure. It has been established that 4-5-8 SON's design, fabrication, and ccnstructicn of the glycol piping is technically equivalent to TVA C1'ss a C (encluding Seismic Category I): and last, it has been shown that the pcst-LOCA environment will not lead to a failure of the glycc1 lines. Therefore, the glycol lines do not constitute a pctential bypass leakage path to the environment.
'a
,[ SG4 - Mn- Ct%
.# Attachment A .
Sheet 6 of y t&M Sunseary y.. v t
/- The secondary containment is provided to mitigate the postulated consequences of hypothetical accidents by enveloping the primary k containment and co11 acting and treating the fission product leakage from primary containment. The secondary containment consists of the annular volume (annulus) around the primary containment and the auxiliary building
- secondary containment enclosure boundary. During a postulated Design Basis Accident (DBA). 3eskage from the primary containment to the ant.ulus may occur. This leakage would be treated by the e.mergency gas treatment
, system (EGTS).
It is alto poselble that, because of piping and valve arrangements, some leakage may bypass the annulus. This leakage from the primary containment i which circumvents the annulus pressure boundary may escape directly into either the auxiliary building or the environment. Bypass leakage to the auxiliary building is defined as that leakage from primary containment which would possibly circumvent the annulus and escape to the auxiliary building durint, a postulated DBA. This leakage will be treated by the Auxiliary Building Gas Treatment System (ABGTS). Bypass leakage to the environment is defined as that leakage from primary containment which '
- would possibly circumvent both the annulus and the auxiliary building. '
allowing the communication of fission products from containment with the environment without being first filtered by either the EGTS or ABGTS.
Background
It is possible that not all primary containment leakage may be collected- ., for the following reason:
- Leakage from the primary containment can bypass the secondary containment through containment penetrations, pipings, and seals which do not terminate in the secondary containment.
Method of Determining tenkere Paths . The Sequoyah containment design was reviewed to identify and evaluate bypass leakage Paths both to the auxiliary building and to the environment. The evaluation of bypass leakage involved the following: j Identification of bypass leakage paths. 1 Determination of leatage rates. penetrations through both the primary and secondary containment may include a number of barriers to leakage such as isolation valves, secls, gaskets, and we'ided joints. While each of these barriers aid in reduction of leakage, they do not necessarily eliminate leakage. Therefore, in identifying potential leakage paths, each of these paths were considered, together with the capacility to test them for leakage in a manner consistent 50 Appendixwith J. the containment leakage tests as required by 10 CFR Part L INFORMATION ONLY E0*d PELO EE9 $19 >i-3153 N05 dMSQ 91:60 / E T/01/2.0
_ _ _ - _ _ - - - - - - - - - - - - - - - - - - - - ~ w w - n u - ct r t. Attachment A s %.. Sheet 7 of WL
,,.4 for design features that would prevent such leakage. penetra features were considered adequate for that purposet The following design Closed systems inside containment.
following requirements: These systems have the The system atmosphere. does not communicate with the primary containment ThesystemhasasafetyclassificationofTVAclassd. The cy : tem it rated to withstand external pressures and temperature to at least the levels of the containment design levels. The system is environmentally quallfled to accideret transients.and the resulting environment. whip, and jets.The system is protected against possible missiles, pipe , Closed systems outelde containment. following requirements: These eystems have the of containment.The system does not communicate with the atmosphere o ' The system has a zafety classification of TVA class C. >
,e .
The internal design pressure and temperature limits, of the temperature limits. system is at least equel to containment design pressu whip, and jets.The system in protected against possible misslies, pipe riuid seal systems in piping. Credit for fluid seals preventing leakage was taken provided the following criteria were satisfind: The thirtyfluid (30)inventory days. was sufficient to assure the seal for The 1 castpressure of at 13.2 psis thealleeal system fluid of the valve was at times. The pressure and inventory criteria for the fluid seal system did not consider a single failure criteria. Gas filled leakate lines with appropriately located valves and inline nipples. and run features: to the auxiliary building, had the following design A third retion or isolation valve was euxiliary buildint,. located outside the annulus INFORMATION ONLY E0*d t'ELO EC9 Sig
>i-D153 tOS do'SBC 43:50 486V03M
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- Attachment A Sheet 8 ofg4+11 One or more inline leskoff nipples was located in the ""
annulus region between the second and third isolation valves.
~
r*. . If a line is isolated by two additionally closed valves in addition to the containment isolation barriers, this line is considered to not be a potential bypass leakage path to the environment. The presence of one or more of the preceding design features in'a potential environment. bypass leakage path was taken to preclude such leakage to the Pathe which penetrate primary containment and which do not terminate
~ within the secondary containment were considered potential bypa paths around the leakage collection and filtration systems of the secondary containment. f evaluated for leakage include: Isolation barriers in these paths which were {
Isolation secondary valves in piping containment which penetrates both the primary and tarriers. l i primary and secondary containment barriers. Seals and 1 Volded joints on penetrations both- the primary-and (guard pipes) which pass throu6h secondary barriers. the paths was also evaluated.In addition to identifyings leakage ,- pati INFORMATION ONLY
! o l Sow-s o s 2 - co ys i l Sheet 9 of 4hn { Ou taPN ATTACHMFNT '3 I l To: D. A. Harrison. Nuclear Engineer From: W. S. Harris. Ccde Engineer ] Su b _i ec t : Glycol piping upgrage from TVA Class N to C l l The following represents reasons why it would not L,c advantageous to recl TVA assi Class f y the N glycol lines from TVA Class N to C. 1s for the design. material .sel ec t i on , fabrication, installation, and testing of refrigeration pining c.n d follows ANSI /ASME B31.5piping power refrigeration
,nd codes. TVA Class C covers the same aspects, but is for follcws USAS E!1.1.0 code for power piping. The TVA commitment for TVA Class C in USAS B31.1.0 -1967 fer desi gn and material sel ec ti on . USAS E31.T - 1969 Class 3 including 1970 addnedum fer fabrication, erection, and testing. B31.7 states: "The requirements for fabrication, assembly, and erection (also examination and testing) of Class III nuclear piping shall be in accordance with USAS E31.1.0 Chapter Y (Chapter VI)."If the intended service was for chilled water, then this wculd not be for carbon a concern steel as the40 piping above two F.codes are very similiar in requirements However, this service is for gl ycol .
B31.5 is a much more stringent code in the areas of design and material selection, but not to for leak testing. In particular. B31.3 addresses Brittle fracture and requires more stringent rules to be follcwed for the
- alculaticn of minimum wall thickness. Although the formula for calculating stress and the stress allowables are the same for A333 Grade B piping. B31.5 recuires the designer to address stress intensification facotra and flexibility stress. E31.5 also places additional limi ts on carbon steel piping in design applications and selection (paragraph 505.1). 331.5 materials in some cases requires more material documentation. Also, B31.5 has stricter impact test requirements for materi al s testing. The ccncern is if the code for this piping is changed to TVA Cl ass C (B31.1.0). then future modifications to this piping would be desianed to a less stringent code and could al so have perscnal safety considerations.
design and material Thisnelection. would actually be a downgrading in the areas of INFORMATION ONLY
W sco- sos 2 - otN B Sheet 10 of -14Nilt
/M hs-n TVA C2 Thoassdocumentation C. It can cniv si mpl y does not exist to prove this =ctually meets Class C.
be proved to be techni call y equivalent to TVA B31.1 requires that the welder be identified and certified and that this piping must be hydroed to 1.5 times the desi gn pressure. This documentation does not now exist. However, (1) SON Construction Fracedures W3 & G3 required a surveillance program which verified that the welders who were picked at random and who were welding during any given shift were avalified End that they were using qualified weld procedures for the welds they were perfarming and that Qualified filler weld materi al was ceing used. It can be thus demonstrated over a period of time that all the welders were qualified L working to qualified procedures with qualified filler material. So even though, the specific welder by name can not be identified, he/she would have had to been qualified and would have been using qualified procedures & materi al s. (C) Even though documentation was not required to be maintained for leak testing (nydros) a search of the documentation for the TVA Class B portions reveals that the piping in question would have been hydroed in conjunction with the TVA Class B due to the location of the fill L drain taps & i solati on valves. Also, when the cognizant engineer signed that the system was complete, he would have been signing that the system had meet the ANSI B31.5 leak test requirements. If this piping is to be cl assi fied TVA Class C. then words must be put in the F5AR and dasign criteria which would specify that this piping would follcw TVA Class C requirements, except that design and material selection would still be in accordance with ANSI EC1.5. h l.$ 4 cuw( Jr. William B. Harris k Code Engineer I l J I l t INFORMATION ONLY I I l \ _____-___________A
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. ENCLOSURE 3' PROPOSED TECHNICAL SPECIFICATION CHANGE -
SEQUOYAH NUCLEAR PLANT (SQN) UNITS l' AND 2 DOCKET NOS. 50-327 AND'50-328 (TVA-SQN-TS-87-33) DETERMINATION OF NO SIGNIFICANT HAZARDS EVALUATION FOR PROPOSED AMENDMENT TO LIMITING CONDITION FOR OPERATION (LCO) 3.6,1.2,
" CONTAINMENT SYSTEMS, CONTAINMENT LEAKAGE"
> I ENCLOSURE 3 SIGNIFICANT HAZARDS EVALUATION
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The proposed amendment would add a definition of " BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING" to the technical specifications and update table 3.6-1 of LCO 3.6.1.2, " Containment Systems, Containment Leakage," to reflect both this definition and the as-built configuration of the plant. This proposed amendment does not involve a change in plant hardware, plant operating setpoints or limits, plant operating procedures, or an increase in potential radiological release to the environment as a result of a postulated design basis accident (DBA). Thus, the proposed technical specification amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
No. As previously stated, the proposed amendment does not involve a change in plant hardware, plant operating setpoints or limits, or plant operating procedures. Thus, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in the margin of safety?
No. Again, as previously stated, the proposed amendment does not involve a change in plant hardwara, plant operating setpoints or limits, plant operating procedures, or an increase in potential radiological releases to the environment as a result of a postulated D3A. The proposed amendment would add a definition for the purpose of clarifying and delineating BYPASS LEAKAGE PATHS TO THE AUXILIARY BUILDING as well as modifying table 3.6-1 to reflect the definition and the current plant configuration. Thus, the proposed amendment involves no reduction in margin of safety but rather, through clarification of terminology and correctly describing current plant configuration, provides for an increase in the margin of safety of the plant. t _ _ _ _ _ _ _ _ _ _ _}}