ML20042E633
| ML20042E633 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 04/20/1990 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20042E628 | List: |
| References | |
| NUDOCS 9004260234 | |
| Download: ML20042E633 (10) | |
Text
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AIIACR1ENI.3 PROPOSED CHANGES TO APPENDIX A,-
TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37, NFF-66. NPF-72 /.NL NPF-77 t
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BYR0!LSIAT10N BRAIDWQDD_STAIl0N Reylaed_fases: 3/4 6-18 Re.rited Passai 3/4 6-18 l 3/4 6-24 3/4 6-24 i
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TABLE 3.6-1 CONTAINMENT ISOLATION VALVES MAXIMUM PENETRATION VALVE NO. FUNCTION ISOLATION TIME (SEC)
- 1. Phase "A" Isolation
)'
28 CV8100 RCP Seal Water Return 10 (
28 CV8112 RCP Seal Water Return 10 )
41 CV8152 RCS Letdown 10 (
41 CV8160 RCS Letdown 10 7
(
5 W9020A Chilled Water 50 5 W9056A Chilled Water 50
/
(
6 W9006A Chilled Water 50 3 Chilled Water 8
8 W9020B W9056B Chilled Water 50 50
(
10 WOOO6B Chilled Water 50 1 c
22 CC9437B* Excess Ltdn HX Return 10 )
48 CC9437A* Excess Ltdn HX Supply 10 (
34 FP010* Fire Protection 12
{
39 39 IA065 IA066 Instrument Air Instrument Air 15 15 q
[
13 OG079 Hydrogen Recombiner 60 )
13 OG080 Hydrogen Recombiner 60 (.
13 OG082 Hydrogen Recombiner 60 )
13 23 23 OG084 OG081 Hydrogen Recombiner Hydrogen Recombiner 60 60
()
OG085 Hydrogen Recombiner 60 69 Hydrogen Recombiner 69 OG057A OG083 Hydrogen Recombiner 60 (
60
)
56 SA032 Service Air 4.5 (
56 SA033 Service Air 4.5 j 80 S0002C 4 Steam Generator Blowdown 7.5 )
80 (
50005B + Steam Generator Blowdown 3.0 81 500020 $ Steam Generator Blowdown 7. 5 82 50002A f Steam Generator Blowdown 7.5 )
82 SD005A
- Steam Generator Blowdown 3.0 )
83 S0002B + Steam Generator Blowdown 7.5 '
88 50002E
- Steam Generator Blowdown 7.5 88 50005C y Steam Generator Blowdown 3.0 -( ,
89 S0002F y 90 Steam Generator Blowdown 7. 5 (
50002G $ Steam Generator Blowdown 7. 5 90 500050V Steam Generator Blowdown 3.0 - {-
91 S0002H X Steam Generator Blowdown 7.5 )
BYRON - UNITS 1 & 2 3/4 6-18 1
d
. I
'O '
TABLE 3.6-1 (Continued)
CONTAINMENT ISOLATION VALVES MAXIMUM PENETRATION VALVE NO. FUNCTION !_ SOLATION TIME (SEC)
- 10. Check (Continued) 60 SIB 819C* Safety Injection N. A.
)
60 518819D* Safety Injection N.A. )
66 SIB 841A" Safety Injection N.A. <
y 66 S!8841B* Safety Injection N.A. ,
73 5189058* Safety Injection N.A. ,
73 SI8905C* *
- Safety Injection N. A.
55 34 SI8968 C FP345*
Safety Injection Fire Protection
. N. A.
N. A.
I (? -
33 CV8368A* RCP Seal Injection N.A. t 33 CV83680* RCP Seal Injection N.A. '
2 53 CV83688* RCP Seal Injection N.A. )
53 CV8368C* RCP Seal Injection N.A. ( ,
11, S/G Safeties /PORVs C ,
77 MS0130* Main Steam N.A. >
77 MS0140* Main Steam . N. A. C.
77 M50150* #
Main Steam N.A. <
77 MS0160* Main Steam N. A. . ~2 77 MS0170* Main Steam N.A. >
78 M5013A* Main Steam N.A. d ,
78 M5014A* Main Steam N.A. C 78 MS015A* Main Steam N. A. )
78 MS016A* Main Steam C N. A. 7 78 M5017A* Main Steam N.A. <
85 MS013B* Main Steam #
N. A.
85 MS014B* Main Steam N. A. C 3 85 M5015B* Main Steam N.A. C 85 MS0168* Main Steam N.A. )
85 M5017B* Main Steam N. A. C 86 MS013C" Main Steam N.A. ..
86 MS014C* Main Steam N.A.
86
)
M5015C* Main Steam N.A.
86 MS016C* Main Steam N. A. -
86 M5017C* Main Steam N.A.
77 MS0180* Main Steam 4
20 '
78 85 M5018A*
MS018B" Main Steam Main Steam 20 y 20 c 86 M5018C* Main Steam 20 )
"Not subject to Type C leakage tests.
- Proper valve operation will be demonstrated by verifying that the valve strokes to its required position. - ,
- May be opened on an intermittent basis under administrative control, j p L .
BYRON - UNITS 1 & 2 3/4 6-24
l TABLE 3.6-1 CONTAINMENT ISOLATION VALVES MAXIMUM l PENETRATION VALVE NO. FUNCTION !
i ISOLATION TIME (SEC) i
- 1. Phase "A" Isolation ,
28 CV8100 RCP Seal Water Return 10 i 28 CV8112 ACP Seal Water Return 10 I 41 CV8152 RCS Letdown 10 41 CV8160 RCS Letdown 10 ,
5 WO20A Chilled Water 50 I 5 WO56A Chilled Water 6
50 )
WOO 6A Chilled Water 50 i 8 WO208 Chilled Water 8
50 ;
WOS68 Chilled Water 50 !
10 WOO 68 Chilled Water '
50 22 CC9437B*
2 48 Excess Ltdn HX Return 10 CC9437A* Excess Ltdn HX Supply 10 i 34 FP010* Fire Protection 12 39 IA065 39 Instrument Air 15 IA066 Instrument Air i ,
15 13 #G079 Hydrogen Recombiner 13 60 SG080 Hydrogen Recombiner 13 60 SG082 Hydrogen Recombiner 13 60 SG084 Hydrogen Recombiner 23 60 '
9G081 Hydrogen Recombiner 23 60 l SG085 Hydrogen Recombiner 69 60 '
DG057A Hydrogen Recombiner '
69 60 9G083 Hydrogen Recombiner 60 -
56 SA032 Service Air 56 4.5 SA033 Service Air 4.5 i
80 SD002C * '
80 Steam Generator Blowdown 7.5 SD005B v Steam Generator Slowdown 81 SD002D +:
3.0 82 Steam Generator Slowdown 7. 5 SD002A
- Steam Generator Blowdown 82 7. 5 ' -
5000$A A Steam Generator 81owdown 3.0 83 SD002B S Steam Generator Blowdown 88 7. 5 .
SD002E 4 Steam Generator Blowdown 7. 5 88 50005C + ;
89 Steam Generator Blowdown -
3.0 -
SD002F 5 Steam Generator Blowdown ' 7. 5 -
90 50002G 4t 90 Steam Generator Blowdown 7. 5 1 S00050 & Steen Generator Blowdown 3.0 91 :
SD002H
- Steam Generator Blowdown 7. 5 '
s BRAIDWOOD - UNITS 1 & 2 3/4 6-18
, t f 4,3 8
TABLE 3.6-1 (Continued)
CONTAINMENT ISOLATION VALVES MAXIMUM PENETRATION VALVE No. FUNCTION ISOLATION TIME (SEC)
- 10. Check (Continued) .
60 $18419C* Safety Injection N.A.
60 $188190* Safety Injection N. A.
66 SI8841A* Safety Injection N.A.
66 $18841B* Safety Injection N.A.
73 $189058* Safety Injection N.A.
73 S18905C* Safety Injection N.A.
55 SI8968 C k *
- Safety Injection N.A. t 34 FP345" Fire Protection N. A.
33 CV8368A" RCP Seal Injection N.A.
33 CV83680* .RCP Seal Injection N. A.
53 CV83688* RCP Seal Injection N. A.
53 CV8368C* RCP Seal Injection N.A.
g
- 11. S/G Safeties /PORVs '
77 MS0130* Main Steam N.A.
77 MS0140* Main Steam N. A.
77 MS0150* Main Steam 77 N.A.
MS01608 Main Steam 77 N.A.
MS017D* Main Steam N.A.
78 MS013A* Main Steam 78 N.A.
M5014A* Main Steam 78 N.A.
MS015A* Main Steam N . /..
78 MS016A* Main 5toam 78 N.A.
MS017A* Main Stoas 85 N.A.
MS0138* Main Steam N.A.
85 MS0148* Main Steam 85 N.A.
MS0158* Main Stoam N.A.
85 MS0168* Main 5 team N.A.
85 MS0178* Main Steam 86 N.A.
MS013C* Main 5 team N. A.
86 MS014C* Main Stoas 86 N.A.
MS015C* Main Stoam N.A.
86 MS016C* Main Stoam 86 N.A.
MS017C* Main Steam N. A. .
77 M50180* Main Steam 20 78 MS018A* Main Steam 85 20 MS0188* Main Steam 20 86 MS018C* Main Steam 20 "Not subject to Type C leaka0e tests.
- Proper valve operation will be demonstrated by verifying that the valve strokes to its required position.
fMay be opened on an intermittent basis under administrative control.
BRAIDWOOD - UNITS 1 & 2 3/4 6-24 .
ATIACEGENI_C EVALUATION OF SIGNIFICANT HA2ARDS_CONEIDIRA110EE Commonwealth Edison Byron Station has evaluated the proposed amendment and determined that it involves no significant hazards consideration. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hasards considerations if operation of the facility in accordance with the proposed amendment would not
- 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 previously evaluated; or
- 3. Involve a significant reduction in margin of safety.
The proposed amendment makes the following changes to Technical Specification 3/4.6.3:
- 1. Deletes the requirement for type C leakage testing for valves 1/2 SD002A through H and 1/2 SD005A through D by inclusion of an "*"
after the above mentioned valves which references the note "*Not subject to Type C leakage tests."
- 2. Deletes the inclusion of an "*" by the 1/2 SI8968 valves. Thus, type C leaka6e testing requirements for the 1/2 SI8968 valves are indicated in the Technical Specification.
- 1. TheJrobability_oLan_ occurrence _or lht_conatsuence of an_accidenLor malfunction _olequipmenLimportankto safsaty_na_prayinualy nyaluated in the UISAILia_naLaignificantly_increaaea for the_reasona_am_Lolloxa.
The deletion of the requirement for type C leakage testing of the steam generator blowdown system (SD) valves is not an initiating condition for any accident analysis in the UFSAR. There are two accident analyses that consider steam generator (SG) blowdown in their analysis. In the first, for the Main Steamline Rupture accident analysis in the UFSAR Table 15.1-2, the SD blowdown valves autoclosure feature is required in the accident analysis not for.the mitigation, but as an assumption for the analysis. Since the SD. valves will still be tested for autoclosure and stroke time when a phase A containment isolation signal is present, the above accident analysis assumption concerning ]
SG blowdown isolation remains satisfied with the change. In the second, for ;
the Steam Generator Tube Rupture (SGTR) accident analysis Table 15.6-5 lists under parameters used in the SGTR analysis the initial condition of 15 gpm
. ATTACllPIENT C (CONT) !
blowdown per SG prior to the accident and no SG blowdown during the accident.
No blowdown is the most conservative assumption for the analysis to maximize l the potential radiological release to the environment since all the primary to secondary leakage (radiological isotopes) would remain in the_ ruptured SG and would not be removed by blowdown. Thus, the proposed change would have no ;
effect on this accident analysis since the most conservative assumption (no blowdown) was used in the analysis and the change would not affect this (any ,
leakage past the blowdown isolation valves would decrease the inventory of radiosotopes 2 eft in the ruptured steam generator that would be available for [
release). .
The SG Blowdown system is not considered in the mitigation of any i accident. With regard to the UFSAR Section 15.2 accident analyses for ,
~
decreased heat sink, the auxiliary feedwater system is the means of mitigation of the accidente. Isolation of SG blowdown conserves the SG secondary side ,
water but does not mitigate the consequence of any accident as described in l the UFSAR. There is no increase, significant or otherwise, in the consequences of an accident previously evaluated in the UFSAR.
Since the secondary side of the SG is considered a closed system meeting the requirements of NUREG 0800 6.2.4.11.6.o. the proposed change would ;
not increase, significantly or otherwise, the probability of a leakage path to the environment. Thus, the 10CFR100 limits would not be significantly ,
affected for any accident analysis. Technical Specification limits on primary to secondary leakage and on both primary and secondary radiation levels would continue to ensure that in the event of an accident the offsite dose limit ,
would remain within a small fraction of the 10CFR100 limits. In the event of a SGTR with some leakage past the SD valves, there would be no effect on the i radiological release in the analysis since the most conservative assumption of no blowdown was used in the analysis. Any leakage past the blowdown valves would be into a blowdown system designed to handle the liquid. The Blowdown '
demineralizer outlet radiation monitor would alarm if leakage occurred.
Various Auxiliary Building area radiation monitors would alarm on elevated-radiation levels in the Auxiliary Building in the event of leakage from the SD system piping to the Auxiliary Building. As designed, the negative pressure in the Auxiliary Building and the Charcoal Booster fans and filters would :
ensure that the radiation would not be released to the environment. Since any leakage would be expected to be a small amount and localized in the Auxiliary Building no adverse consequences would result. There would be no significant effect on any accident analysis. i l Thus, for the above reasons, the proposed change of deletion of type C testing for the SD valves does not significantly increase the probability of
, an occurrence or the consequence of an accident, or malfunction of equipment Important to safety as previously evaluated in the UFSAR.
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. ATTACIDtENT C (CONT) s The inclusion of type C testing for the SI8968 valves is a change of j an editorial nature and merely corrects,the Technical Specification to make it consistent with the UFSAR. The SI8968 valves have always required type C testing per 10CTR50 Appendix J, and the testing has always been done. For j this reason,'the change does not significantly increase the probability of an 1 occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR.
- 2. The_ possibility _for an acrident or malfunction _of a diffarant typ.e_than any_prerinualy.evalual_ed in_the UfSAR is not cregt.c.d. '
The SD system is Category 1 Safety Class B piping up to and including the !
isolation valves, and has manual isolation valves.- With respect to the !
accident analysis in Section 15.2 of the UFSAR where there is a decrease in the heat removal by the secondary system, SG blowdown isolation is not required to mitigate any of the accidents in the analysis. Auxiliary feedwater initiation mitigates the accidents. The amount of leakage is insignificant with respect to the total SG secondary water mass. Though the ,
SD isolation valves do autoclose on a phase A containment isolation signal to conserve SG secondary side mass, this is not required to mitigate the effects of any accident in the UFSAR. No other accident or malfunction would be created. Thus, the possibility for an accident or malf unction of a different -
type than any previously created in the UFSAR is not created.
The change to include the type C leakage test for SI8968 valves does not create the possibility for an accident or malfunction of a different type than any previously analyzed, since the change is of an editorial nature and reflects the-type of testing already done since it has been required.
- 3. The._ margin _o Lsafety_as_deLiaed_in_the_hasis Lor anv Technical S pe cific a tion _ia_noLaignificantly_. reduced .
Pursuant to NUREG 0800 6.2.4.II.6.o the SG secondary is a closed system and therefore does not meet the 100FR50 Appendix J criteria for type C leakage testing. That is, no direct path would exist from containment to the outside atmosphere which might result in a radiological release to the environment and as such, satisfies its containment isolation function without type C terting requirements. Technical Specification limits on-primary to secondary leakage and both primary and secondary radiation-limits ensure that in the event of an accident (in particular, a SGTR), the offsite dose limits would be only a
- small portion of the 100FR100 limits. The containment isolation function of ,
l the SD valves is to coaserve the SG secondary side mass in the event of an accident. Surveillances to verify autoclosure and stroke time ensure that the SD valves are functionally operable. The bases for containment isolation valves Technical Specification 3/4.6.3, is that "the operability of the containment isolation valves ensures that the containment atmosphere will be isolated from l
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,,, AIIACEtiggi c (cQNT) the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment." (Technical Specification 3/4.6.3 Bases p. B 3/4 6-4). This would be satisfied with the proposed change. Thus, the margin of safety as defined in the bases for any Technical Specification is not significantly reduced.
The change to require type C testing for the S18968 valves is of an editorial nature and does not reduce the margin of safety as defined in the basis for any Technical Specification.
Therefore, based on the above evaluation. Commonwealth Edison believes that these changes do not involve a significant' hazards consideration.
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A27ACEEEllT D EEVIRONMENTAL ASSESSMENT STATDfENT APPLICABILITY REVIEW Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 100FR51.21. The proposed amendment meets the eligibility criteria for categorical exclusion set forth in 100FR51.22(c)(9) in that:
- 1. The proposed amendment involves no significant hazards consideration s.3ee Attachment C);
- 2. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and
- 3. There is no significant increase in individual or cumulative occupational radiation exposure.
Pursuant to 10CFR51.22(b), no environmental assessment or environmental impact statement is required with the issuance of the proposed amendment.
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