ML021150397

Technical Specifications, Issuance of Amendments (Tac Nos. MB3758 and MB3759)

ML021150397
Person / Time
Site:	Catawba
Issue date:	04/23/2002
From:	NRC/NRR/DLPM
To:
Shared Package
ML021160169	List: ML021140431 ML021150397
References
TAC MB3758, TAC MB3759
Download: ML021150397 (22)

Text

CRAVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Area Ventilation System (CRAVS)

LCO 3.7.10 Two CRAVS trains shall be OPERABLE.

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N O- T E -------------------------------------------------

The control room pressure boundary may be opened intermittently under administrative controls.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRAVS train A.1 Restore CRAVS train to 7 days inoperable in MODES OPERABLE status.

1,2,3,4,5, and 6.

B. Two CRAVS trains B.1 Restore control room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable due to pressure boundary to inoperable control room OPERABLE status.

pressure boundary in MODES 1, 2, 3, or 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1,2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Catawba Units 1 and 2 3.7.10-1 Anmhmnt 1bs. 198/191

CRAVS 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CRAVS Immediately associated Completion train in operation.

Time of Condition A not met in MODE 5 or 6.

E. Two CRAVS trains E.1 Suspend movement of Immediately inoperable in MODE 5 irradiated fuel assemblies.

or 6, or one or more CRAVS trains inoperable during movement of irradiated fuel assemblies.

F. Two CRAVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

(continued)

Catawba Units 1 and 2 3.7.10-2 Ana-dmnt Nos. 198/191

CRACWS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Area Chilled Water System (CRACWS)

LCO 3.7.11 Two CRACWS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of recently irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRACWS train A.1 Restore CRACWS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met in MODE 1,2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C. Required Action and C.1 Place OPERABLE Immediately associated Completion CRACWS train in Time of Condition A not operation.

met in MODE 5 or 6, or during movement of OR recently irradiated fuel assemblies. C.2 Suspend movement of Immediately recently irradiated fuel assemblies.

(continued)

Catawba Units 1 and 2 3.7.11-1 CAnmdh t Nbs. 198/191

CRACWS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two CRACWS trains D.1 Suspend movement of Immediately inoperable in MODE 5 recently irradiated fuel or 6, or during assemblies.

movement of recently irradiated fuel assemblies.

E. Two CRACWS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify the control room temperature is < 90 0 F. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Catawba Units 1 and 2 3.7.1 1-2 aA*ffaent Nos. 198/191 I

FHVES 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Fuel Handling Ventilation Exhaust System (FHVES)

LCO 3.7.13 Two FHVES trains shall be OPERABLE and one train in operation.

APPLICABILITY: During movement of recently irradiated fuel assemblies in the fuel building.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more FHVES -------------- NOTE ---------

trains inoperable. LCO 3.0.3 is not applicable.

A.1 Suspend movement of Immediately recently irradiated fuel assemblies in the fuel building.

B. Required FHVES train B.1 Restore FHVES train 7 days heater inoperable, heater to OPERABLE status.

OR B.2 Initiate action in 7 days accordance with Specification 5.6.6.

Catawba Units 1 and 2 3.7.13-1 Anmit NTs. 198/191 I

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by a minimum of four bolts;

b. A minimum of one door in each air lock closed; and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. exhausting through an OPERABLE Containment Purge Exhaust System (CPES) HEPA filter and charcoal adsorber.

APPLICABILITY: During movement of recently irradiated fuel assemblies within I containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend movement of Immediately containment recently irradiated fuel penetrations not in assemblies within required status. containment.

(continued)

Catawba Units 1 and 2 3.9.3-1 aArr- t Nos. 198/191 I

CRAVS B 3.7.10 BASES LCO (continued)

OPERABLE to ensure that at least one is available assuming a single failure disables the other train. Total system failure could result in exceeding a dose of 5 rem to the control room operator in the event of a large radioactive release.

The CRAVS is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains. A CRAVS train is OPERABLE when the associated:

a. Pressurizing filter train fan is OPERABLE;

b. HEPA filters and carbon adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room pressure boundary must be maintained, including the integrity of the walls, floors, roof, ductwork, and access doors.

The CRAVS is shared between the two units. The system must be OPERABLE for each unit when that unit is in the MODE of Applicability.

Additionally, both normal and emergency power must also be OPERABLE because the system is shared. If a CRAVS component becomes inoperable, or normal or emergency power to a CRAVS component becomes inoperable, then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of applicability of the LCO.

The LCO is modified by a Note allowing the control room pressure boundary to be opened intermittently under administrative controls. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room pressure boundary isolation is indicated.

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, CRAVS must be OPERABLE to control operator exposure during and following a DBA.

Catawba Units 1 and 2 B 3.7.10-3 Revision No. /4

CRAVS B 3.7.10 BASES APPLICABILITY (continued)

During movement of irradiated fuel assemblies, the CRAVS must be OPERABLE to cope with the release from a fuel handling accident.

ACTIONS A.1 When one CRAVS train is inoperable in MODES 1,2,3,4,5,or 6, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CRAVS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CRAVS train could result in loss of CRAVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1 If the control room pressure boundary is inoperable in MODES 1, 2, 3, or 4 such that the CRAVS trains cannot establish or maintain the required pressure, action must be taken to restore an OPERABLE control room pressure boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the period that the control room pressure boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period and the use of compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room pressure boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CRAVS or control room pressure boundary train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Catawba Units 1 and 2 B 3.7.10-4 Revision No. 3

CRAVS B 3.7.10 BASES ACTIONS (continued)

D.1 In MODE 5 or 6, if the inoperable CRAVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CRAVS train in operation.

This action ensures that the operating (or running) train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

E.1 In MODE 5 or 6, with two CRAVS trains inoperable, or during movement of irradiated fuel assemblies with one or more CRAVS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

F. 1 If both CRAVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than Condition B, the CRAVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

G. 1 and G.2 With one or more CRAVS heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Specification 5.6.6, which details the reason for the heater's inoperability and the corrective action required to return the Catawba Units 1 and 2 B 3.7.10-5 Revision No. 4

CRAVS B 3.7.10 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.10.4 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rate (or makeup rate) assumed in the dose analysis.

The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the CRAVS. The CRAVS is designed to pressurize the control room > 0.125 inches water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The CRAVS is designed to maintain this positive pressure with one train at a makeup flow rate of < 4000 cfm. The Frequency of 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 6).

REFERENCES 1. UFSAR, Section 6.4.

2. UFSAR, Section 9.4.1

3. UFSAR, Chapter 15.

4. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

5. Regulatory Guide 1.52, Rev. 2.

6. NUREG-0800, Section 6.4, Rev. 2, July 1981.

7. 10 CFR 50.67, Accident Source Term.

8. Regulatory Guide 1.183, Revision 0.

Catawba Units 1 and 2 B 3.7.10-7 Revision No. 2

CRACWS B 3.7.11 BASES LCO Two independent and redundant trains of the CRACWS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disabling the other train. Total system failure could result in the equipment operating temperature exceeding limits in the event of an accident.

The CRACWS is considered to be OPERABLE when the individual components necessary to maintain the control room temperature are OPERABLE in both trains. These components include a chiller package, chilled water pump, and air handling unit. In addition, the CRACWS must be operable to the extent that air circulation can be maintained.

The CRACWS is shared between the two units. The system must be OPERABLE for each unit when that unit is in the MODE of Applicability.

Additionally, both normal and emergency power must also be OPERABLE because the system is shared. If a CRACWS component becomes inoperable, or normal or emergency power to a CRACWS component becomes inoperable, then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of applicability of the LCO.

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of recently irradiated fuel assemblies, the CRACWS must be OPERABLE to ensure that the control room temperature will not exceed equipment operational requirements following a design basis accident. The CRACWS is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) due to radioactive decay.

ACTIONS A._1 With one CRACWS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CRACWS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a single failure in the OPERABLE CRACWS train could result in loss of CRACWS function. The 30 day Completion Time is based on the low probability of an event, the consideration that the remaining train can provide the required protection, and that alternate safety or nonsafety related cooling means are available.

Catawba Units 1 and 2 B 3.7.11-2 Revision Nol i

CRACWS B 3.7.11 BASES ACTIONS (continued)

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable CRACWS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1 and C.2 In MODE 5 or 6, or during movement of recently irradiated fuel, if the inoperable CRACWS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CRACWS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, and that active failures will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

D.1 In MODE 5 or 6, or during movement of recently irradiated fuel assemblies, with two CRACWS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

E.1 If both CRACWS trains are inoperable in MODE 1, 2, 3, or 4, the control room CRACWS may not be capable of performing its intended function.

Therefore, LCO 3.0.3 must be entered immediately.

Catawba Units 1 and 2 B 3.7.11-3 Revision No.1I

CRACWS B 3.7.11 BASES SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to maintain the temperature in the control room at or below 90 0 F. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is appropriate since significant degradation of the CRACWS is slow and is not expected over this time period.

REFERENCES 1. UFSAR, Section 9.4.

2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

3. 10 CFR 50.67, Accident source term.

4. Regulatory Guide 1.183, Revision 0.

Catawba Units 1 and 2 B 3.7.11-4 Revision No. I I

FHVES B 3.7.13 B 3.7 PLANT SYSTEMS B 3.7.13 Fuel Handling Ventilation Exhaust System (FHVES)

BASES BACKGROUND The FHVES filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. The FHVES, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel pool area.

The FHVES consists of two independent and redundant trains with two filter units per train. Each filter unit consists of a heater, a prefilter, high efficiency particulate air (HEPA) filters, an activated carbon adsorber section for removal of gaseous activity (principally iodines), and a fan.

Ductwork, valves or dampers, and instrumentation also form part of the system. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case the main HEPA filter bank fails. The downstream HEPA filter is not credited in the analysis, but serves to collect carbon fines, and to back up the upstream HEPA filter should it develop a leak. The system initiates filtered ventilation of the fuel handling building following receipt of a high radiation signal.

The FHVES train does not actuate on any signal. One train is required to be in operation whenever recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is being moved in the fuel handling building. The operation of one train of FHVES ensures, if a fuel handling accident occurs, ventilation exhaust will be filtered before being released to the environment. The prefilters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and carbon adsorbers.

The FHVES is discussed in the UFSAR, Sections 6.5, 9.4, and 15.7 (Refs. 1, 2, and 3, respectively) because it may be used for normal, as well as atmospheric cleanup functions after a fuel handling accident in the spent fuel pool area.

APPLICABLE The FHVES design basis is established by the consequences of SAFETY ANALYSES the applicable Design Basis Accidents (DBA), which are the fuel handling accident involving handling recently irradiated fuel and the weir gate drop accident. The analysis of the fuel handling accident assumes that all fuel rods in an assembly are damaged. The DBA analysis of the fuel handling Catawba Units 1 and 2 B 3.7.13-1 Revision No.2

FHVES B 3.7.13 BASES APPLICABLE SAFETY ANALYSES (continued) accident assumes that only one train of the FHVES is in operation. The amount of fission products available for release from the fuel handling building is determined for a fuel handling accident. These assumptions and the analysis follow the guidance provided in Regulatory Guide 1.25 (Ref. 4) and 1.183 (Ref. 10).

The FHVES satisfies Criterion 3 of 10 CFR 50.36 (Ref. 5).

LCO Two trains of the FHVES are required to be OPERABLE and one train in operation whenever recently irradiated fuel is being moved in the fuel handling building. Total system failure could result in the atmospheric release from the fuel handling building exceeding the 10 CFR 100 (Ref. 6) limits in the event of a fuel handling accident involving handling recently irradiated fuel.

The FHVES is considered OPERABLE when the individual components necessary to control exposure in the fuel handling building are OPERABLE. An FHVES train is considered OPERABLE when its associated:

a. Fans are OPERABLE;

b. HEPA filters and carbon adsorbers are not excessively restricting flow, and are capable of performing their filtration function; and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

APPLICABILITY During movement of recently irradiated fuel in the fuel handling area, the I

FHVES is required to be OPERABLE and in operation to alleviate the consequences of a fuel handling accident.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

With the movement of recently irradiated fuel in the fuel handling building, two trains of FHVES are required to be OPERABLE and one in operation.

The movement of recently irradiated fuel must be immediately Catawba Units 1 and 2 B 3.7.13-2 Revision No. 2 I

FHVES B 3.7.13 BASES ACTIONS (continued) suspended, if one or more trains of FHVES are inoperable or one is not in operation. This does not preclude the movement of an irradiated fuel assembly to a safe position. This action ensures that a fuel handling accident with unacceptable consequences could not occur.

B.1 and B.2 With one or more FHVES heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Specification 5.6.6, which details the reason for the heater's inoperability and the corrective action required to return the heater to OPERABLE status.

The heaters do not affect OPERABILITY of the FHVES filter trains because charcoal adsorber efficiency testing is performed at 300C and 95% relative humidity. The accident analysis shows that site boundary radiation doses are within 10 CFR 100 limits during a DBA LOCA under these conditions.

SURVEILLANCE SR 3.7.13.1 REQUIREMENTS With the FHVES train in service, a periodic monitoring of the system for proper operation should be checked on a routine basis to ensure that the system is functioning properly. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is sufficient to ensure proper operation through the HEPA and charcoal filters and is based on the known reliability of the equipment.

SR 3.7.13.2 Systems should be checked periodically to ensure that they function properly. As the environmental and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.

Monthly heater operation dries out any moisture accumulated in the carbon from humidity in the ambient air. Systems with heaters must be operated from the control room for > 10 continuous hours with flow through the HEPA filters and charcoal adsorbers and with the heaters energized. The 31 day Frequency is based on the known reliability of the equipment.

Catawba Units 1 and 2 B 3.7.13-3 Revision No. 1 1

FHVES B 3.7.13 BASES REFERENCES 1. UFSAR, Section 6.5.

2. UFSAR, Section 9.4.

3. UFSAR, Section 15.7.

4. Regulatory Guide 1.25.

5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

6. 10 CFR 100.

7. Regulatory Guide 1.52 (Rev. 2).

8. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

9. 10 CFR 50.67, Accident source term.

10. Regulatory Guide 1.183 (Rev. 0).

Catawba Units 1 and 2 B 3.7.13-5 Revision No. 1

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During movement of recently irradiated fuel assemblies (i.e., fuel assemblies that have occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. During movement of recently irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for Catawba Units 1 and 2 B 3.9.3-1 Revision No.2 I

Containment Penetrations B 3.9.3 BASES BACKGROUND (continued) extended periods when frequent containment entry is necessary. During movement of recently irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed.

The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment. The closure restrictions are sufficient to restrict fission product radioactivity release from containment due to a fuel handling accident involving recently irradiated fuel during refueling.

The Containment Purge Exhaust System includes two trains. Purge air is exhausted from the containment through the Containment Purge Exhaust System to the unit vent where it is monitored for radioactivity level by the unit vent monitor prior to release to the atmosphere. The Containment Purge Exhaust System consists of two 50 percent capacity filter trains and fans. There is one purge exhaust duct penetration through the Reactor Building wall from the annulus area. There are three purge exhaust penetrations through the containment vessel, two from the upper compartment and one from the lower compartment. Two normally closed isolation valves at each penetration through the containment vessel provide containment isolation. One normally closed isolation damper at the Reactor Building wall provides annulus isolation.

The upper compartment purge exhaust ductwork is arranged to draw exhaust air into a plenum around the periphery of the refueling canal, effecting a ventilation sweep of the canal during the refueling process.

The lower compartment purge exhaust ductwork is arranged so as to sweep the reactor well during the refueling process.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

Equivalent isolation methods must be approved and may include use of a material that can provide a temporary, atmospheric pressure, ventilation barrier for the other containment penetrations during recently irradiated fuel movements.

APPLICABLE During movement of recently irradiated fuel assemblies within SAFETY ANALYSES containment, the most severe radiological consequences result from a fuel handling accident involving recently irradiated fuel. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents, analyzed in Reference 2, include Catawba Units 1 and 2 B 3.9.3-2 Revision No. 1 1

Containment Penetrations B 3.9.3 BASES APPLICABLE SAFETY ANALYSES (continued) dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Cavity Water Level," and the minimum decay time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without containment closure capability ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100. Standard Review Plan, Section 15.7.4, Rev. 1 (Ref. 2),

defines "well within" 10 CFR 100 to be 25% or less of the 10 CFR 100 values. The acceptance limits for offsite radiation exposure will be 25% of 10 CFR 100 values or the NRC staff approved licensing basis (e.g., a specified fraction of 10 CFR 100 limits).

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LCO This LCO limits the consequences of a fuel handling accident involving handling recently irradiated fuel in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for penetrations exhausting through an OPERABLE Containment Purge Exhaust System HEPA filter and charcoal adsorber during movement of recently irradiated fuel assemblies.

APPLICABILITY The containment penetration requirements are applicable during movement of recently irradiated fuel assemblies within containment because this is when there is a potential for the limiting fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when movement of recently irradiated fuel assemblies within containment is not being conducted, the potential for a limiting fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

During movement of recently irradiated fuel assemblies, ventilation system and radiation monitor availability (as defined by NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the RCS decays fairly rapidly.

The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay, and to avoid unmonitored releases.

A single normal or contingency method to promptly close primary or secondary containment penetrations exists. Such prompt methods need Catawba Units 1 and 2 B 3.9.3-3 Revision No. 1 1

Containment Penetrations B 3.9.3 BASES APPLICABILITY (continued) not completely block the penetration or be capable of resisting pressure.

The purpose is to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper directions such that it can be treated and monitored.

ACTIONS A.1 and A.2 If the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending movement of recently irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

B.1 and B.2 With one or more Containment Purge Exhaust System heaters inoperable, the heater must be restored to OPERABLE status within 7 days. Alternatively, a report must be initiated per Specification 5.6.6, which details the reason for the heater's inoperability and the corrective action required to return the heater to OPERABLE status.

The heaters do not affect OPERABILITY of the Containment Purge Exhaust System filter trains because charcoal adsorber efficiency testing is performed at 300 C and 95% relative humidity. The accident analysis shows that site boundary radiation doses are within 10 CFR 100 limits during a DBA LOCA under these conditions.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are exhausting through an OPERABLE Containment Purge Exhaust System HEPA Filter and charcoal adsorber.

The Surveillance is performed every 7 days during movement of recently irradiated fuel assemblies within containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. As such, this Surveillance ensures that a postulated fuel handling accident involving recently irradiated fuel that Catawba Units 1 and 2 B 3.9.3-4 Revision No. 1 I

Containment Penetrations B 3.9.3 BASES SURVEILLANCE REQUIREMENTS (continued) releases fission product radioactivity within the containment will not result in a release of significant fission product radioactivity to the environment.

SR 3.9.3.2 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system. Monthly heater operations dry out any moisture that may have accumulated in the charcoal from humidity in the ambient air. Systems with heaters must be operated by initiating flow through the HEPA filters and activated carbon adsorbers for > 10 continuous hours with the heaters energized. The 31 day Frequency is based on the known reliability of equipment and the two train redundance available.

SR 3.9.3.3 This SR verifies that the required testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The Containment Purge Exhaust System filter tests are in accordance with Reference 4. The VFTP includes testing HEPA filter performance, charcoal adsorbers efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

REFERENCES 1. UFSAR, Section 15.7.4.

2. NUREG-0800, Section 15.7.4, Rev. 1, July 1981.

3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

4. Regulatory Guide 1.52 (Rev. 2).

5. 10 CFR 50.67, Accident source term.

6. Regulatory Guide 1.183 (Rev. 0).

Catawba Units 1 and 2 B 3.9.3-5 Revision No. 1 1