ML17254A603

Proposed Tech Specs,Incorporating New Containment mini-purge Sys & Deleting Requirements Associated W/Old 48-inch Containment Purge Sys

ML17254A603
Person / Time
Site:	Ginna
Issue date:	10/22/1985
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17254A600	List: ML17254A599 ML17254A601 ML17254A603
References
NUDOCS 8510220379
Download: ML17254A603 (21)

Text

Attachment A Revise the Technical Specification pages as follows:

Remove Insert 3.5-22 3.5-22 3.6-5 3.6-5 3.6-6 3.6-6 3.6-7 3.6-7 3".6-7A

'.6-11 3.6-11 3.8-1 3.8-1 4.4-7 4.4-7 4.4-8 4.4-8 jjg102>.

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I TABLE 3.5-7, Radiation Accident Monitorin Instrumentation Minimum Channels Instrument ~Oerable Action

1. Containment Area (R-29 and R-30)

2. Noble Gas Effluent Monitors Plant Vent (R-14) ii. A Main Steam Line (R-31) iii. B Main Steam Line (R-32) iv. Containment Purge (R-12A) v ~ Air Ejector (R-15A)

Action Statements Action 1 With the number of operable channels less than required by the Minimum Channels Operable requirements, either restore the inoperable channel(s) to operable status within 7 days of the event, or prepare and submit a Special Report to the Commission within 30 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to operable status.

• only when the shutdown purge system flanges are removed.

3.5-22 Proposed

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MAXKMUM MMGMUM PENT. ISOZATION ISOZATION ISOZATION ISOZATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME *(SEC) BOUNDAHY TIME *(SEC) 121 Nitrogen to PRT CV 528 MV 547(8) 121 Reactor Makeup water to PRT CV 529 AOV 508 60 121 Cont. Press. transmitter PT-945 (10) PT 945 MV 1819A 121 Cont. Press. transmitter PT-946 (10) PT 946 MV 1819B 123 Reactor Coolant Drain Tank (RCDT) to (R AOV 1789 60 MV 1655(7) 124 Excess letdown supply and return AOV 745 60 to heat exchanger CV 743 124 Post Accident air sample "C" fan MV 1569 MV 1571 MV 1572 MV 1574

..125 Canponent Gooling Water (CW) fran 1B RCP MOV 759B (12) 126 QOW fran 1A RCP MOV 759A (12) 127 CV 750A MOV 749A 60 128 CV 750B MOV 749B 60 e 129 E

RCDT 8( PRT to Vent Header AOV 1787 60 AQV 1786 60 CV 1713 g 130 -

CCW to reactor support cooling MOV 813 60 131 QOW to reactor support cooling MOV 814 60 (19) 132 blini-Purge exhaust AOV 7970 AOV 7971 140 --RHR pump suction fran "A" Hot leg MOV 701(20) (6)

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C MAXIMUM HAXIMUM PENT. ISOLATION ISOLATION ISOLATION ISOLATION NO. IDENTIFICATION/DESCRIPTION BOUNDARY TIME ='(SEC) BOUNDARY TIME "-(SEC) 141 RHR-//1 pump suction from Sump B MOV 850A(13) NA MOV 851A(13) NA 142 RHR-jj2 pump suction from Sump B MOV 850B(13) NA MOV 851B(13) NA 143 RCDT pump suction AOV 1721 60 AOV 1003A 60 AOV 1003B 60 201 Reactor Compart. cooling Unit A 6 B MV 4757(16) NA MV 4636(16) NA NA 202 "B" Hydrogen recombiner (pilot 6 main) MV 1076B NA SOV IV-3B NA Normally Closed MV 1084B NA SOV IV-5B NA Normally 'Closed 203 Contain, Press. transmitter PT-947 S 948 PT 947 NA MV 1819C NA PT 948 NA MV 1819D NA 203 Post accident air sample to "B" fan MV 1563 NA MV 1565 NA MV 1566 NA MV 1568 NA 204 Shutdown Purge Supply Duct flange (22) NA AOV 5869 (22) 205 Hot leg loop sample AOV 966C 60 MV 956D(14) NA 206 Zrzr. liquid space sample AOV 966B 60 MV 956E(14) NA 206 "A" S/G sample AOV 5735 60 MV 5733(7) NA 207 Przr. Steam space sample AOV 966A 60 MV 956F NA 0

207 "B" S/G sample AOV 5736 60 MV 5734(7) .NA 209 Reactor Compart. cooling Units A 8 B MV 4758(16) NA NA MV 4635(16) NA NA 210 Oxygen makeup to A 8 B recombiners MV 1080A NA SOV IV-2A NA Normally Closed SOV IV-2B NA Normally Closed

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MAXIMUM MAXIMUM PENT. ISOLATION IsoLAnom

- -IsoLAnoN IsoI,Anom No. IDENTIFICATION/DESCRIPTION BOUNDARY TIME " (SEC) BOUNDARY TIME "(SEC) 300 Shutdown Purge Exhaust Duct flange (22) NA AOV 5879 (22) 301 Aux. steam supply to containment MV 6151 NA - MV 6165(15) NA 303 Aux. steam condensate return MV 6175 NA -MV 6152(15) NA 304 "A" Hydrogen recombiner (pilot and main) MV 1084B NA SOV IV-5A NA Normallly Clos~

MV 1076A NA . SOV XV-3A NA NormaU.ly Clo~

305 Radiation Monitors R-ll, R-12 S R-10A AOV 1597 60 ~

MV 1596 NA Auto Inlet Isol.

305 R-ll, R-12 S R-10A Outlet AOV 1599 60 AOV 1598 60 305 Post Accident air sampler (containment) MV 1554 NA MV 1556 60 MV 1557 NA MV 1559 NA MV 1560 NA MV 1562 NA

't 307 Fire Service Water CV 9229 NA -AOV 9227 (18) 308 Service Water to "A" fan cooler MV 4627(16) NA NA 309 Mini-Purge supply AOV 7478 AOV 7445 310 Service Air to Contain. CV 7226 NA MV 7141 NA 310 Instrument Air to Contain. CV 5393 NA AOV 5392 60 0

~o 311 Service Water from "B" fan cooler MV 4630(16) NA NA 312 Service Water to "D" fan cooler MV 4642(16) NA.

313 Ieakage test depressurization flange NA MOV 7444 NA Normally Closed

MAXIMUM MAXDIUM PENT. ISOZATION ISOZATION ISOZATION NO. IDENTIFICATION/DESCBIPTION TIME *(SEC) TIME *(SEC)

Service Water fran "C" fan cooler MV 4643(16) 316 Service Water to "B" fan cooler MV 4628(16) 317 Leakage test supply flange MOV 7443 Nh. Normally Closed 318 Dead weight tester (deccmissioned) welded shut welded shut Service Water frcm "A" fan cooler MV 4629(16) 320 Service water to "C" fan cooler MV 4647(16) 321 A S/G Blmrdown AOV 5738 60 MV 5701(7)

~ 322 B S/G Blcwdown AOV 5737 60 MV 5702(7) 323 Service Water frcm "D" fan cooler MV 4644(16) 324 Demineralized water to Containment CV 8419 AOV 8418 332 Cont. Press. Trans. PT-944, 949 6 950 PT 944 MV 1819G PT 949 MV 1819F 332 Leakage test and hydrogen instrumentation lines mnitor PT 950 MV 7448 MV 7452 MV 1819E cap cap

.0 MV 7456 cap SOV 921 (21)

SOV 922 (21)

SOV 923 (21)

SOV 924 (21)

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(21) Acceptable isolation capability is provided for instrument lines by two isolation boundaries outside containment. One of the boundaries outside containment may be a Seismic Class 1 closed system which is subjected to Type C leak rate testing.

(22) The flanges at penetrations 204 and 300 can only be removed at cold or refueling shutdown. The flanges and associated double seals provide containment isolation and are a containment boundary for all modes of operation between cold shutdown and normal operation. During cold and refueling shutdown when the flanges are removed integrity is provided by the 48 inch valves.

3.6-11 Proposed

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~ v 3.8 REFUEZING A licabilit Applies to operating limitations during refueling operations.

~b'o ensure that no incident could occur during refueling operations that would affect public health and safety.

3.8.1 During refueling operations the following conditions shall be satisfied.

a ~ The equipment door, or a closure plate that restricts air flow from the containment, and at least one personnel door in the equipment door or closure plate and in the personnel air lock shall be properly closed. In addition, all automatic containment isolation valves shall be operable or at least one valve in each line I

shall be',locked closed. The" 48 inch "shutdown lt purge valves must also be operable or closed or the associated flange must be installed'.

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b. Radiation levels in the containment shall be monitored continuously.

c ~ Core subcritical neutron flux shall be contin-uously monitored by at least two source range neutron monitors, each with continuous visual .

indication in the control room and one with audible indication in the contairpnent and control room available whenever core geometry is being changed. When core geometry is not being changed at 3.8-1 Proposed

v shutdown and depressurized until repairs are effected and the local leakage meets the acceptance criterion.

4.4.2.4 Test Fre uenc a ~ Except as specified in b., c., and d. below, individual penetrations and containment isolation valves shall be tested during each reactor shutdown for refueling, or other convenient intervals, but in no case at, intervals greater than two years.

b. The containment equipment hatch, fuel transfer tube, and shutdown purge system flanges shall be tested at each refueling shutdown or after each n

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The, containment,air'o'cks'hall be tested at,

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intervals of no more than six months by pressurizing the space between the air lock doors. In addition, following opening of the air lock door during the interval, a test shall be performed by pressurizing between the dual seals of each door opened, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the opening, unless the reactor was in the cold shutdown condition at the time of the opening or has been subsequently brought to the cold shutdown condition. A test shall also be performed by pressurizing between the dual seals of each door within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of leaving the cold shutdown condition, unless the doors have not been open since the last test performed either by pressurizing the space between the air lock doors or by pressurizing between the dual door seals.

4.4-7 Proposed

4.4.3 Recirculation e t e ov l S stems 4.4.3.1 Test a ~ The portion of the residual heat removal system that is outside the containment shall either be tested by use in normal operation or hydrostati-cally tested at 350 psig at the interval specified in 4.4.3.4.

b. Suction piping from containment sump B to the reactor coolant drain tank pump and the discharge piping from the pumps to the residual heat removal system shall be hydrostatically gested at go less that 100 psig at the interval specified

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in $ .4.3.4.

4. 4-,8 Proposed

Attachment B Containment purge and vent operations became a generic concern in 1978. Since that time containment purge and vent has been the subject of many letters between the Staff and Rochester Gas and Electric Corp. (RG&E). In Reference 1, the Staff transmitted to RGSE a Safety Evaluation Report (SER) which found RGE's interium commitments to be acceptable. The SER provides a good summary of the correspondance and the commitments made concerning this subject.

The existing purge and vent systems at Ginna consist of a 48 inch purge system and a 6 inch containment vent (depressurization) system. The major issue concerning the purge system is the operability of the 48 inch purge valves during a design basis accident loss of coolant accident (DBA-LOCA). Therefore, RGGE has committed to maintaining the 48 inch purge valves closed while the reactor is critical until information demonstrating operability is submitted.

In response to the Staff's request to limit purge/vent operations to safety-related needs RG6E committed to limiting vent system operation to a total of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year.

To permanently resolve the purge and vent issue RG6E has decided to modify the 48 inch purge system so that it will only be used when the reactor is in cold or refueling shutdown, and install a mini-purge system which will allow unlimited purging of containment.

The technical specification changes presented in Attachment A are necessary to implement these modifications.

The following changes will be made to the 48 inch purge system:

The inboard 48 inch, butterfly-type containment isolation valves from both the supply and exhaust lines will be removed. Each valve will be replaced with a, special blind-flange type closure utilizing double 0-ring seals to provide redundant containment isolation barriers. Test ports will be provided.to permit peri-odic local leak rate testing of the double,O-ring seal. "The blind flange closures will be securely bolted,in place,,dur'ing .

reactor operation and will only be'removed during plant shutdowns.

The existing outboard 48 inch, butterfly-type automatic containment.

isolation valves will remain in place to provide an isolation barrier during refueling operations.

Since the blank flanges have a double seal, it will no longer be necessary to rely on the outer 48 inch valves for containment isolation during power operation. During cold or refueling shutdown, the flanges could be removed and the outer valves will be relied upon for refueling integrity. Since the 48 inch valves are no longer relied upon for containment integrity the mechanical stops on the valves will be removed. These stops were installed to reduce stresses in the valves resulting from closure during a DBA-LOCA. Since the valves 'are no longer subject to a DBA-LOCA there is no reason to continue restricting air flow in the 48 inch system during shutdown.

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A new mini-purge system will be installed to provide the capability to purge containment atmosphere during all modes of This 2000-cfm mini-purge system will consist of a reactor'peration.

pair of redundant blowers for supplying'air to the containment through existing 6-inch Integrated Leak Rate Test (ILRT) vent line penetration 309. "New 6 i*nch, air'-. operated, butterfly-type, inboard and outboar'd automatic containment isolation valves will be installed at penetration 309. Air will be exhausted through the existing 6 inch depressurization penetration 132 and will be ducted into the Auxiliary Building ventilation system where will be filtered and monitored prior to its release to the envi-it ronment via the plant vent. The existing 6 inch valves at pene-tration 132 will be replaced with new 8 inch, air-operated, butterfly-type, inboard and outboard containment. isolation valves.

All four new containment isolation valves will be automatic and will be fully-qualified to close within 5 seconds from the time the isolation setpoint is reached against the maximum containment pressures anticipated during a DBA-LOCA. The inboard ends of the mini-purge supply and exhaust lines will be equipped with 1/2-inch mesh debris screens.

The radiation accident monitor R-12A (Containment Purge) monitors the 48 inch purge exhaust. Since the 48 inch purge will only be operable during cold and refueling shutdown, R-12A need only be operable during cold and refueling shutdown. Therefore, Table 3.5-7 was modified to be consistant with operation of the shutdown purge system.

In accordance with 10 CFR 50.91, these changes to the Technical Specifications have been evaluated against three criteria to determine if the operation of the facility in accordance with proposed amendment would:

1. involve a significant increase in the probability or consequences of an accident previously evaluated; or

2. create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. involve a significant reduction in a margin of safety.

The modification does not involve an increase in the probability or consequences of an accident previously evaluated. Installing a mini-purge system and installing flanges on the 48 inch valves does not increase the probability of an accident because the flanges eliminate the effects of any malfunction of the 48 inch valves and the new mini-purge valves are small and inherently more reliable than the 48. inch valves. The consequences of any previously evaluated accident are not increased by the modification because the flanges prevent any accident associated with the 48 inch system and clearly any accident associated with the mini-purge system is less limiting than an accident associated with the 48 inch sytem.

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The modification does not create the possibility of a new or different kind of accident. Replacing the 48 inch purge system with a mini-purge system basically decreases the size of the purge system and therefore does not create a new or different kind of accident.

The modification does not significantly reduce the margin of safety because the con'sequences of any accident with the mini-purge system would be less severe than an accident associated with the 48 inch system.

As outlined above, Rochester Gas and Electric submits that the issues associated with this amendment request are outside the criteria of 10 CFR 50.91, and therefore, a no significant hazards finding is warranted.

Reference 1 NRC letter from D.M. Crutchfield to R.W. Kober, "Completion of Generic Issue On Containment Purge and Vent Operation" June 21, 1984.

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