ML20136F823

Proposed Tech Specs 3/4.6.3 Re Containment Isolation Valves Surveillance Requirements

ML20136F823
Person / Time
Site:	Farley
Issue date:	03/07/1997
From:	SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML20136F818	List: ML20136F814 ML20136F823
References
NUDOCS 9703170067
Download: ML20136F823 (10)

Text

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, , ENCLOSURE 1 -

l Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications

, Containment Isolation Valves Surveillance Requirements i

Basis for Change Request i The proposed changes would revise Technical Specification (TS) Surveillance a

Requirements 4.6.3.2 for both Unit I and Unit 2. The TS changes would allow the I demonstration of operability of the containment iwation valves while the unit is in a i defueled state. Currently, the TS require the operability demonstration to be performed 1 during either the Cold Shutdown Mode or the Refueling Mode (e.g. Mode 5 or Mode 6, respectively). When the plant is in a defueled state, by the TS definitions, it is in no mode of operation. Because of the specific wording that presently exists, the cperability of the  ;

containment isolation valves cannot be performed when the probability of the need for the I containment isolation valves to automatically initiate is at the lowest risk level. This area l of concern was suitably addressed when the improved Westinghouse Standard Technical 1 Specifications (STS) NUREG-1431, Revision I were issued on April 7,1995. These changes are technically consistent with the requirements of the STS.

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. , ' ENCLOSURE 2 i l Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications )

. Containment Isolation Valves Surveillance Requirements 10 CFR 50.92 Evaluation d

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Pursuant to 10 CFR 50.92 each application for amendment to an operating license must be l

reviewed to determine if the proposed change involves a significant hazards consideration.  !

The amendment, as defined belov 1escribing the Technical Specifications changes to the j i- Containment Isolation Valves St. ..llance Requirements has been reviewed and deemed I

. not to involve a signi6 cant hazards consideration. The basis for this determination .

follows.

I BACKGROUND r l

.The purpose of containment isolation is to ensure that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to l

, the containment atmosphere or pressurization of the containment. The containment  ;

j isolation valves specified in Table 3.6-1 of the Unit I and Unit 2 Technical Specifications i are required to meet certain operability requirements. These operability requirements are l 4

given in Surveillance Requirement (SR) 4.6.3.2 of the TS. Also named in SR 4.6.3.2 are

operating Modes of a unit during which the operability of the valves must be tested.

These Modes are specifically, Cold Shutdown (Mode 5) and Refueling Mode (Mode 6).

When a unit is in e defueled state, by the definition of the Modes in the Technical

Specifications, the unit is not in an operational Mode; therefore, the operability of the containment isolation valves cannot be performed during a defueled state.

DESCRIPTION OF CHANGE REOUEST 4 The proposed changes would revise SR 4.6.3.2 for both Unit I and Unit 2 to allow the demonstration of operability of the containment isolation valves while a unit is in a

defueled state. When a unit is defueled, the risk of the occurrence of a release of the j radioactive material to the containment atmosphere or pressurization of the containment is

far less than when a unit is either in Mode 5 or Mode 6. These proposed changes are i technically consistent with the improved Westinghouse Standard Technical Specifications i l (STS), NUREG-1431, Revision 1 issued on April 7,1995.

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Enclosure 2 10 CFR 50.92 Evaluation ANALYSIS ]

Allowance to test containment isolation while a unit is in a defueled state will continue to meet the necessary intent of the operability test requirements. For the valves to be tested appropriately, the systems to which they are connected should continue to be providing

the same temperature, pressure and/or flow that the valve would experience if they were called upon to perform their function in the event of an accident. These proposed l changes are technically consistent with the requirements of NUREG-1431, Revision I which has already received the requisite review and approval of the NRC staff.

10 CFR 50.92 EVALUATION CONCLUSIONS

- Based on the preading evaluation, the following conclusions are provided with respect j to the criteria contained in 10 CFR 50.92.

(1) The proposed changes do not significantly increase the probability or consequences 4

of an accident previously evaluated in the FSAR. The proposed changes have no q

, impact on the probability of an accident. The containment isolation valves will l continue to require operability testing. Allowing the testing to be performed when

. the unit is in a defueled status will have no impact on any accidents previously evaluated. The net effect'of these changes is not significant and, as a result, does not  ;

. involve a significant increase in the consequences of an accident previously ,

evaluated.

(2) The proposed changes to the Technical Specifications do not increase the possibility j of a new or different kind of accident than any accident already evaluated in the l FSAR. No new limiting single failure or accident scenario has been created or identified due to the proposed changes. Safety-related systems will continue to perform as designed. The proposed changes do not create the possibility of a new or i

different kind of accident from any previously evaluated.

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, Enclosure 2 10 CFR 50.92 Evaluation (3) The proposed changes do not involve a significant reduction in the margin of safety.

Although, as a result of these proposed changes, the containment isolation valves

could be tested for operability while the unit is in a defueled state, there is no impact in the accident analyses. These proposed changes are technically consistent with the requirements of NUREG-1431, Revision I which has already received the requisite review and approval of the NRC staff. Thus the proposed changes do not involve a significant reduction in the margin of safety.

' Accordingly, Southern Nuclear Operating Company has determined that the proposed changes with respect to the Containment Isolation Valves Surveillance Requirements do not involve a significant hazards consideration.

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ENCLOSURE 3 i'

Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Containment Isolation Valves Surveillance Requirements l

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,. CONTAfNMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.6.3.2 Each isolation valve specified in Table 3.6-1 shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELIt1G MODES or defueled at least once per 18 months by:

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a. Verifying that on a Phase A containment isolation test signal, each Phase A isolation valve actuates to its isolation position.

b. Verifying that on a Phase B containment isolation test signal, I each Phase B isolation valve actuates to its isolation position. 1 4.6.3.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to .

Specification 4.0.5.

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4.6.3.4 The containment purge isolation valves shall be demonstrated OPERABLE prior to startup after each COLD SHUTDOWN if not performed in the previous 3 months by verifying that when the measured leakage rate is added to the leakage rates for all other Type B and C penetrations, the combined leakage rate is less than or equal to 0.60L., In addition, the leakage rate for the containment purge isolation valves shall be compared to the previously l measured leakage rate (for the containment purge isolation valves) to detect excess valve degradation.

An engineering evaluation shall be performed to determine what corrective action, if any, is necessary.

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l 1 l CONTATNMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) l i

4.6.3.2 Each isolation valve specified in Table 3.6-1 shall be I demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODES or defueled at least once per 18 months by: l I

a. Verifying that on a Phase A containment isolation test signal, each Phase A isolation valve actuates to its isolation position.

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b. ' Verifying that on a Phase B containment isolation test signal, '

each Phase B isolation valve actuates to its isolation position.

4.6.3.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

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4.6.3.4 The containment purge isolation valves shall be demonctrated OPERABLE prior to start *1p after each COLD SHUTDOWN if not performed in the previous 3 months by verifying that when the measured leakage rate is added to the leakage rates for all other Type B and C penetrations, the combined leaksge rate is less than or equal to 0.60L,. In addition, the leakage rate for the containment purge isolation valves shall be compared to the previously l 1

measured leakage rate (for the containment purge isolation valves) to detect l excess valve degradation.

An engineering evaluation shall be performed to determine what corrective l

action, if any, is necessary.

FARLEY-UNIT 2 3/4 6-15 AMENDMENT NO.

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. ENCLOSURE 4 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications -

Containment Isolathn Valves Surveillance Requirements I 1

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AtntvIILIJutCE REQUIREMENTS (Continued)

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4.6.3.2 Bach isolation valve specified in Table 3.6-1 sha 1 he

! demonstrated OPERABLE during the COLD 551TfDOWN or REFUELING at least once per 18 months by:

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a. Verifying that on a Phase A containment isolation test signal, each Phase A imelation valve actuates to its isolation position.

b. Verifying that on a Phase 3 containment isolation test signal, each Phase 5 isolation valve actuates to its isolation position. l

{ 4.6.3.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to

specification 4.0.5. i i

l 4.6.3.4 The contmia-mat purge imelation valves shall be demonstrated l OPERAELE prior to startup after each COLD SEUTDONN if not perfocused in the 1 previous 3 soonths by verifying that when the measured leakage rate is added to 3 the leakage rates for all other Type 5 and C penetrations, the combined l l leakage rate le less than or egnal to 0.60La. In additima, the leakage rate j for the contalament purge imelation vcive) shall he compared to the previously measured leakage rate (for the oestaiament purge isolation valves) to detect '

j excess valve degradation.

An engineering evaluation shall be perforced to determine,what corrective i

action, if any, is necessary.

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l FARLEY-UNIT 1 3/4 6-15 AMENDMENT NO.122

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, CONTAfttMENT SYSTEMS i 66 or de ku ed j ,

sURVEILuutCE RIgCIREMENTS (Continued) i

4.6.3.2 Bach isolation valve specified in Table 3.6-1 sha 1, be i demonstrated OPERAILE during the COLD SEUTDomt or REFUELING at least once

! per 18 months by i

l a. Verifying that on a Phase A containment isolation test ei. pal,

, each Phase A isolation valve actuates to its isolation position.

I i b. Verifying that on a Phase a containment isolation test signal,

! sach Phase B isolation valve actuates to its isolation positt, '

f 4.6.3.3 The isolation time of each power operated or automatic valve

! Table 3.6-1 shall be determined to be within its limit when tested pursuant to

! oecification 4.0.5.

l 4.6.3.4 The containment purge isolation valves shall be demonetrated )

. g OPERABLE prior to startup after each CIX.D SEUTDONE if not performed in the l \ previous 3 emeths by verifying that when the meneered leakage rate is added to

the leakage rates for all' other Typo 5 and C peestrations, the combined l i leakage rate is less than or equal to 0.60La. In addition, the leakage rate j for the containment purge isolation valves shall be compared to the previously l esseured leakage rate (for the contain-mat purge isolation valves) to deteet ,

excess valve degradation.

i An engineering evaluation shall be performed to determine what corrective

• i action, if any, is necessary.

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FARLEY-UNIT 2 3/4 6-15 AMENDMENT HQ. II4