ML20247R649

Proposed Tech Specs,Adding Necessary Statements to Allow for Periodic Cycling of Pneumatically Operated Vq Valves Per Mfg Recommendations

ML20247R649
Person / Time
Site:	LaSalle
Issue date:	06/01/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20247R646	List: ML20247R642 ML20247R649
References
0148T, 148T, NUDOCS 8906070284
Download: ML20247R649 (16)

Text

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l AHACIMENT B ERDEOSEp CHANGES TO THE TECHNICAL SPECIFICATIONS FOR OPERATING LICENSIS M F-11.AMD E F-18 Revised Pages:

NPF-11 NPF-10 3/4 6-15 3/4 6-18 B 3/4 6-2 B 3/4 6-2 014BT:6 p

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CONTAINMENT SYSTEMS  ;

DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM

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-LIMITING CONDITION FOR OPERATION _

3.6.1.8 The drywell and suppression chamber purge system may be in operation with the drywell and/or suppression chamber purge supply and exhaust butterfly isolation valves open for inerting, de-inerting and pressure control. Purging through the Standby Gas Treatment System shall be restricted to less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION:

With a drywell and/or suppression chamber purge supply and/or exhaust butterfly

'isiolation valve open for other than inerting, de-inerting or pre'ssure control,

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close the butterfly valve (s) within one hour or be in at least HOT SHUf00WN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

INSERT b>Ewl PAgAGRAPH (. SE E. REKT PAGE )

SURVEILLANCE REQUIREMENTS

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4.6.1.8.1 The cumulative time that the drywell and suppression chamber purge system has been in operation purging through the Standby Gas Treatment System shall be verified to be less than or eq9al to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365. days prior to use in this mode of operation. ,

LA SALLE - UNIT 1 3/4 6-15 Amendment No. 37

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PARAGRAPH INSERT FOR PAGE 5/# 6 With more than one drywell or suppression chamber' purge system supply or exhaust butterfly isolation valve open, in any purge system primary containment penetration, for any purpose other than inerting,-de-inerting or pressure control, close at least one of the isolation valves in the affected primary containment penetration within one hour or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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CONTAINMENT SYSTEMS BASES -

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3/4.6.1.5 PRIMARY CONTAINMENT STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of the containment will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the containment will withstand the maximum pressure of 45 psig in the event of a LOCA. The measurement of containment tendon lift-off force, the tensile tests of the tendon wires or strands, the visual examination of tendons, anchorages and exposed interior and exterior surfaces of the containment, the chemical and visual examination of the sheathing filler grease, and the Type' A leakage test are sufficient to demonstrate this capability.

The surveillance requirements for demonstrating the primary containment's structural integrity and the method of predicting the pre-stress loses are in compliance with the recommendations of Regulatory Guide 1.35.1, " Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containment Structures,",

January 1976, and proposed Regulatory Guide 1.35.1, " Determining Prestressing Forces for Inspection of Prestressed Concrete Containment St'ructures,"

April 1979 with the following clarification: the tested lift-off force of individual tendon tension shall be greater than or equal to the initial pre-stress minus the loses, as predicted in the as-built design, which occur between the initial pre-operational structural integrity test and the time of subsequent surveillance.

The required Special Reports from any engineering evaluation or contain-ment abnormalities shall include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedure, the tolerances on cracking, the results of the engineering evalua-tion, and the corrective action taken.

3/4.6.1.6 DRYWELL AND SUPPRESSION CHAMBER INTERNAL PRESSURE The ifmitations on -drywell and suppression chamber internal pressure ensure that the containment peak pressure of 39.6 psig does not. exceed the l

design pressure of 45 psig during LOCA conditions or that the external pres-sure differential does not exceed the design maximum external pressure differen-l tial of 5 psid. The limit of 2.0 psig for initial positive primary containment pressure will. limit the total pressure to 39.6 psig which is less than the design pressure and is consistent with the accident analysis.

i 3/4.6.1.7 DRYWELL AVERAGE AIR TEMPERATURE l

The limitation on drywell average air temperature ensures that the containment peak air temperature does not exceed the design temperature of 340 F during LOCA conditions and is consistent with the accident analysis.

3/4.6.1.8 ORYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM AT trasT opg oFfhe dryWell and suppression chamber purge $s'uYply M exhaust isolation valvep,are required to be closed during plant operation except as required l for inerting, de-inerting and pressure control. These valves have been I

demonstrated capable of closing during a LOCA or steam line break acci_ dent from the full open position. +/ <c.rrer *M err uur w r.e roc ,ua r ]

w es en runs sysrsu perma y coarswmWT PEWErEA T I of LA SALLE UNIT 1 8 3/4 6-2 Amendment :;. n

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l' The system.is. considered in operation when more than one butterfly valve in any containment penetration. is open.

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1 CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM LIMITING CONDITION FOR OPERATION

3. 6.1. 8 The drywell and suppression chamber purge system may be in operation with the drywell and/or suppression chamber purge supply and exhaust butterfly isolation valves open for inerting, deinerting, and pressure control. Purging l through the Standby Gas Treatment System siall be restricted to less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION: -

INSERT NEW PAR AG,RA PH ( SEE NEXT PAGE )

With a drywell and/or suppression chamber purge supply and/or exhaust butt l isolation valve open for other than inerting, deinerting, or pressure control, I g

close the butterfly valve (s) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT SHUTDOWN with-in the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTOOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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SURVEILLANCE REQUIREMENTS

... l 4.6.1.8.1 The cumulative time that the drywell and suppression chamber purge I system has been in operation purging through the Standby Gas Treatment System shall be verified to be less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days prior to use in this mode of operation.

p LA SALLE - UNIT 2 3/4 6-18 Amendment No. 25

.m-PARAGRAPH INSERT P'oR PAGE 5/4 fr-la With more than one drywell or suppression chamber purge system supply or exhaust butterfly isolation valve open, in any purge system primary containment penetration, for any purpose other than inerting, de-inerting or pressure control, close at least one of the isolation valves in the affected primary containment penetration within one hour or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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CONTAINMENT SYSTEMS l BASES-j 3/4.6.1.5 ' PRIMARY CONTAINMENT STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of:the containment- ,

will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the containment:

will withstand the maximum pressure of 45 psig in the event of a LOCA.- The measurement of containment tendon lift-off force, the tensile tests of the tendon wires or strands, the visual examination of tendons, anchorages and exposed interior and exterior surfaces of the containment, the chemical and visual examination of the sheathing filler. grease, and the Type A leakage test are sufficient to demonstrate this capability.

The surveillance' requirements for demonstrating the primary containment's structural integrity and the.nethod'of predicting the prestress losses are in compliance with the recommendations of Regulatory Guide 1;35, " Inservice Inspection of Ungrouted. Tendons in Prestressed Concrete Containment Structures,"

January 1976, and proposed Regulatory Guide 1.35.1 " Determining Prestressing Forces for Inspection of Prestressed Concrete Containment Structures," April 1979 with the following clarification: the tested lift-off force of individual-tendon tension shall be greater than or equal to the initial prestress minus the losses, as predicted in the as-built design, which occur between the initial pre-operational structural integrity test and the time of subsequent surveillance.

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The. required Special Reports from any engineering evaluation of contain-ment abnormalities shall include a description of the tendon condition, the condition of the concrete (es'ecially p at tendon anchorages), the inspection procedure, the tolerances on cracking, the results of the engineering evalua-tion, and the corrective action taken.

3/4.6.1.6 . DRWELL' AND SUPPRESSION CHAMER INTERNAL. PRESSURE The limitations on drywell and suppression chamber internal pressure ensure that the contaiheent peak pressure of 39.6 psig does not exceed the design pressure of 45 psig during LOCA conditions or.that the external pres-sure differential does not exceed the design maximum external pressure differen-tial of 5 psid. The limit of 2.0 psig for initial positive primary containment-pressure will limit the total pressure to 39.6 psig which is less than the design pressure and is consistent with the safety analysis.

3/4.6.1.7 DRWELL AVERAGE AIR TEMPERATURE The limitation on drywell average air temperature ensures that the containment peak air temperature does not exceen the design temperature of 340'F during LOCA conditions and is consistent with the safety analysis.

3/4.6.1.8 DRWELL AND SUPPRESSION CHAMBER PURGE SYSTEM eR SY3 TEM OR AT' LEMT ONE OF ,7'he dryWell end suppression Chamber purge 3 supply and exhaust isolation

( valves, re required to be closed during plant operation except as required for i rting, de-inerting and pressure contro). These valves have been demo trated capable of closing durina a LOCA or steam lirte break =crident --

frc the full open position./ wsser T', 5EE m7 A d r FOR W SER T_/ l LA SALLE UNIT 2 B 3/4 6-2 Amendment No. 25

-w cAcH PURGE SYSTEM PM/ ONr%E'M T pen rR Nrma ,

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l The system is considered in operation when more than one butterfly valve in any containment penetration is open, j E

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SIGNIFICANT HAZARDS CQbtf,IDERATION Commonwealth Edison has evaluated the proposed Technical Specification amendment and determined that it does not represent a significant hazards consideration. Based on the criteria for-defining a significant hazards consideration establised in 10 CFR 50.92, operation of LaSalle County Station Units 1 and 2, in accordance with the proposed amendment, will nQ1:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated because This change does not affect the original system design of venting or purging the primary containment. Operation with one valve closed assures primary containment integrity.

(2) Create the possibility of a new ot different kind of accident from any accident previously evaluated because:

This change does not affect the original system design or venting or purging the primary contalument which is designed to have both valves in the containment penetrat'on open.

(3) Involve a significant reduction in the margin of safety because:

Primary containment is still maintained with only one of the two valves open in each penetration and the open valve is still subject to closure by a primary containment isolation signal.

Guidance has been provided in 51.44 FR 7744 (Reference I.C.2.e.li) for the application of standares to license change requests for determination of the existence of significant hazards considerations. This document provides examples of mnendments which are and are not likely considered to involve significant hazards considerations.

This proposed amendment does not involves a significant relaxation of the criteria used to establish safety limits, a significant relaxation of the bases.for the limiting safety system settings or a significant relexation of the bases for the limiting limiting conditions for operationc. Thetefore, based on the guidance provided in the Federal Register and the criteria established in 10 CFR 50.92(e), the proposed change does not constitute a significant hazards consideration.

0148T 7

i ATEhC1MW1.D ADD H IT_AL_EUEP.QRT MATERIAL 0148T/3 8

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'- AMENDMENT 24 C' LSCS-FSAR

. SEPTEMBER 1977

='(*0 QUESTION 021.28 "Regarding the containment purge system, our position is provided in the enclosed Branch Technical Position CSB 6-4, Containment Purging During Normal Plant Opera'-

tion.' Provide an evaluation of the containment purge system based upon this branch technica3 position."

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RESPONSE

By NRC lettar of July 21, 1977-from Mr. Olan Parr to Mr. Byron Lee of Commonwealth Edison Company, the applicant'is not required to identify conformance to Standard Review Plans and supporting Branch Technical Positions except where a prior issue:was identified on the C-P docket. The contain-ment purge system was not so identified.

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• LSCS-FSAR~ AMENDMENT 57 JULY 1981 b OUESTION~021.54 "Your' response to Question 021.28 (containment purge

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-system) i;s inadequate. It is our position that the -

requirements outlinedzin Branch Technical Position CSB 6-4 (See SRP pg. 6.2.4-10) be met. Therefore, provide the appropriate. discussions, justifications and analyses to demonstrate your compliance."

RESPONSE

The primary containment p, urge system for the La Salle County station is sized for use during hot shutdown, cold shutdown and refueling operatiend. The requirements outlined in the Branch Technical Position CSB 6-4 pertain to the use of the containment purge system during normal power operation. l I

At La Salle, 2-inch bypass lines exist.in the drywell vent system to bleed-off excess primary containment pressure during~ opera, tion (valves VQ068 and VQO35).

The containment purge isolation valves (26-inch butterfly valves) are designed not to exceed a 50' open position.

An operability demonstration program for the purge isolation

.. i valves shall be completed.

L-An evaluation of the primary containment vent and purge system with respect to the criteria specified in BTP CSB 6-4 is presented in the following summary.

The 2-inch bypass line, which can be classified as the "on-line purge trystem" in the terminology of BTP CSB 6-4, is not totally independent of the purge system used during shutdown and refueling. The "on-line" system shares a common containment penetration on the inboard side, and shares the entire remaining vent system'on the downstream side of the inboard isolation valve. Therefore, the only portion that is independent is the bypass line, bypass valve and valve controls.

The remaining evaluation is presented in the itemized format with which BTP CSB 6-4 establishes the criteria:

la. The purge bypass and isolation valves, line and controls are designed as Quality Group B components.' The design criteria for the valve and line include the pressure, temperature, flow, and other environmental conditions associated with closure following a DBA in the containment.

, .- Therefore, the LSCS design complies with this

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• criterion.

Q21.54-1

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LSCS-FSAR AMENDMENT 57 JULY 1981 1,q -

CA:'I '1b.- One vent line is,provided for the drywell and L

'one. vent line is provided for the suppression

chamber area. Administrative controls prevent

' both of these bypass valves from, being opened . -

concurrently. Only the drywell bypass valve can be opened in the' operating or hot shutdown modes. Therefore, LSCS.is in compliance with.

the criterion.

1c. 'The maximum 8-inch size limit established by.

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this.NRC criterion is met by the 2-inch bypass L line, but not by the 26-inch main vent line.

However, the' radiological consequence analysis performed for BTP CSB 6-4 (Item Sa) demonstrates:

compliance with the intent of the; maximum 6-inch size limit by the 26-inch vent line.

Id. The isolation provisions for the bypass and main lines fully comply with_the required standards- '

of an engineered safety feature.

le. .The instrumentation and controls provided to isolate the vent lines comply with the stated

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' criteria.

v if.- The' bypass valve closure times are specified to be 5 seconds, as required. Isolation valves

' closure times are 40 seconds, as required for

- compliance with 10 CFR 100 limits.

19 Provisions have been made to install screens on vent _line openings to prevent debris from entering the vent lines. However, no great amounts of debris are anticipated, and it appears highly improbable that-debris would be thrown directly into the_ vent line opening. The instal-lation of the debris screens will be completed during the first refueling.

2. The purge system:is not relied on for temperature and humidity control within the containment.

• The primary containment ventilation system performs this function.

, 3. No containment atmosphere cleanup system has .

been provided within the primary containment.

However, such a system is provided within second-1 ary containment at LSCS.

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LSCS-FSAR AMENDMENT ,

.3 e e JULY 1981-

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4. Provisions to perform leakage tests in compliance kh with 10 CFR-50. Appendix.J have been made..

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However, these provisions do.not' include. testing-

, during reactor operation.J .

The1 ann 1ysis.of,theradiologicalconsequences

< Sa.

associated-with a' loss-of-coolant accident; while operating.the bypass or main ventfline

'has been performed. The radiologicalLconsequences1 associated with blowdown lthrough a 2-inch valve. g for 5' seconds or a 26-inch valve for 40 seconds y would.not be significant for La Salle's elevated' stock release.

Sb. The 2-inch line blows down into a'26-inch line which is capable of withstanding thel peak drywell

. pressure. The. purge' system would be venting' through the non-safety-related containment.

atmosphere cleanup system.which'could potentially

-be. damaged by the: blowdown, although this'has.

.no safety significance.

The: cross-tie to the SGTS is isolated by a damper which:is capable.of withstanding the E, resultant pressures in" the cross-tie .line.

n(; .Therefore,fthe blowdown has no' detrimental effectsLon safety-related equipment.

Sc. There will be no significant reduction in con-tainnent pressure resulting from'the blowdown

.through the bypass line.. 'Furthermore, this reduction would have no effect:cn BCCS performance,

'since the ECCS pumps are' sized'for atmospheric.

suction pressure. No credit is'taken.for contain-ment prassure acting on the pump' suction.

5d. Leakage rates on the purge and vent isolation valves a.:e based on complying with the limits establist'ed by the Technical Specifications-and 10 CFR 50, Appendix J, and.are periodically 7 testedito verity their adequacy.

In ' summary, - although the LSCS ' primary. containment vent and purge bypass-line does not connly explicitly to the BTP CSB 6-4 criteria,-the design and operation of this bypass line meets.the functional intent of the criteria. When coupled with the extremely unlikely event of a LOCA occurring while the' containment-is being vented, it is concluded that an1 adequate safety design basis, exists for the ve.nt and

+ - purge system.

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AMENDHENT 57 l .:_

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LSCS-FSAR JULY 1981 l

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1. In addition to the above operations, the secondary containment can be purged independently through the cleanup filter trains of the purge system. During this mode of operation, the primary containment vent lines are isolated via the regular.

isolation valves. ,

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Q21.54-4

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