ML033070057

Tech Spec Page Changes for Amendment Regarding Closure of the Containment Building Equipment Door During Movement of Irradiated Fuel

ML033070057
Person / Time
Site:	Sequoyah
Issue date:	10/28/2003
From:	Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
TAC MB7238, TAC MB7239
Download: ML033070057 (4)

Text

REFUELING OPERATIONS 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS LIMITING CONDITION FOR OPERATION 3.9.4 The containment building penetrations shall be in the following status:

a. The equipment door closed and held in place by a minimum of four bolts,

b. A minimum of one door in each airlock Is closed, and both doors of both containment personnel airlocks may be open If:

1. One personnel airlock door In each airlock is capable of closure, and

2. One train of the Auxiliary Building Gas Treatment System is OPERABLE in accordance with Technical Specification 3.9.12, and

c. Each penetration* providing direct access from the containment atmosphere'to the outside atmosphere shall be either:

1. Closed by an isolation valve, blind flange, manual valve, or equivalent, or

2. Be capable of being closed by an OPERABLE automatic Containment Ventilation isolation valve.

APPLICABILTY:

3.9.4.a. Containment Building Equipment Door - During movement of recently Irradiated fuel within the containment.

3.9.4.b. and c. Containment Building Airlock Doors and Penetrations - During movement of Irradiated fuel within the containment.

ACTION:

1. With the requirements of the above specification not satisfied for the containment building equipment door, immediately suspend all operations Involving movement of recently Irradiated fuel in the containment building. The provisions of Specification 3.0.3 are not applicable.

2. With the requirements of the above specification not satisfied for containment airlock doors or penetrations, immediately suspend all operations Involving movement of irradiated fuel in the containment building. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.4 Each of the above required containment building penetrations shall be determined to be either In Its required condition or capable of being closed by an OPERABLE automatic Containment Ventilation isolation valve once per 7 days during movement of irradiated fuel in the containment building by:

a. Verifying the penetrations are In their required condition, or

b. Testing the Containment Ventilation isolation valves per the applicable portions of Specification 4.6.3.2.

• Penetration flow path(s) providing direct access from the containment atmosphere that transverse and terminate In the Auxiliary Building Secondary Containment Enclosure may be unisolated under administrative controls.

SEQUOYAH - UNIT 1 3/4 9-4 Amendment No. 12, 209, 249, 260, 288

314.9 REFUELING OPERATIONS BASES 314.9.1 BORON CONCENTRATION The limitations on reactivity conditions during REFUELING ensure that: 1) the reactor will remain subcritical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel. Maintaining the listed valves in the closed position precludes an uncontrolled boron dilution accident by closing the flow paths for possible sources of unborated water. These limitations are consistent with the initial conditions assumed for the boron dilution Incident in the accident analyses.

314.9.2 INSTRUMENTATION The OPERABILITY of the source range neutron flux monitors ensures that redundant monitoring capability is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of Irradiated fuel assemblies In the reactor pressure vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay time is consistent with the assumptions used In the accident analyses.

3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment building penetration closure and OPERABILITY ensure that a significant release of radioactive material within containment will be restricted from leakage to the environment. The OPERABILITY and closure restrictions are sufficient to restrict radioactive material release from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING MODE. Containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be Isolated on at least one side during movement of irradiated fuel. The containment building equipment door must be closed during movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />). 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 containment penetrations during fuel movements. Both sets of the containment personnel airlock doors may be open during movement of irradiated fuel in containment provided one train of Auxiliary Building Gas Treatment System (ABGTS) Is available for manual operation. The basis of this is that SQN is analyzed for a fuel handling accident (FHA) in either the containment or the auxiliary building; however, a manual ABGTS start may be necessary for a containment FHA. The requirement for an airlock door to be capable of closure Is provided to allow for long-term recovery from a FHA In containment.

During movement of Irradiated fuel assemblies, a single normal or contingency method to promptly close the containment building equipment door will be in place. Such prompt methods need 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.

The LCO is modified by a footnote allowing penetration flow paths with direct access from the containment atmosphere to the Auxiliary Building Secondary Containment Enclosure (ABSCE) to be unisolated under administrative controls. These flow paths must be within the ABSCE structure or In qualified piping that constitutes the ABSCE boundary and either terminate or have an Isolation device within the ABSCE. Administrative controls ensure that 1)appropriate personnel are aware of the open status of the penetration flow path during movement of Irradiated fuel assemblies within containment, 2) specified Individuals are designated and readily available to Isolate the flow path in the event of an FHA, and 3) one train of the ABGTS is OPERABLE In accordance with Technical Specification 3.9.12. As discussed above for the containment airlock doors, the basis for this allowance is the SQN analysis for an FHA in containment or the auxiliary building and the potential need for a manual start of the ABGTS for an FHA In containment. This allowance Is not applicable to the containment ventilation isolation flow paths because of the potential motive force associated with the containment purge system that could result In additional releases of radioactivity. Additionally, this allowance is not applicable to those flow paths that terminate or are routed outside the ABSCE in piping that does not meet the requirements for an ABSCE boundary.

SEQUOYAH - UNIT 1 B 314 9-1 Amendment No. 209, 249, 260, 288

REFUELING OPERATIONS 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS LIMITING CONDITION FOR OPERATION 3.9.4 The containment building penetrations shall be Inthe following status:

a. The equipment door closed and held In place by a minimum of four bolts,

b. A minimum of one door In each airlock is closed, or both doors of both containment personnel airlocks may be open if:

1. One personnel airlock door in each airlock Is capable of closure, and

2. One train of the Auxiliary Building Gas Treatment System Is OPERABLE In accordance with Technical Specification 3.9.12, and

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

1. Closed by an isolation valve, blind flange, manual valve, or equivalent, or

2. Be capable of being dosed by an OPERABLE automatic Containment Ventilation isolation valve.

APPLICABILITY:

3.9.4.a. Containment Building Equipment Door - During movement of recently irradiated fuel within the containment.

3.9.4.b. and c. Containment Building Airlock Doors and Penetrations - During movement of irradiated fuel within the containment ACTION:

1. With the requirements of the above specification not satisfied for the containment building equipment door, immediately suspend all operations involving movement of recently irradiated fuel in the containment building. The provisions of Specification 3.0.3 are not applicable.

2. With the requirements of the above specification not satisfied for containment airlock doors or penetrations, immediately suspend all operations involving movement of irradiated fuel In the containment building. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.4 Each of the above required containment building penetrations shall be determined to be either in its required condition or capable of being closed by an OPERABLE automatic Containment Ventilation isolation valve once per 7 days during movement of irradiated fuel in the containment building by:

a. Verifying the penetrations are in their required condition, or

b. Testing the Containment Ventilation Isolation valves per the applicable portions of Specification 4.6.3.2.

• Penetration flow path(s) providing direct access from the containment atmosphere that transverse and terminate in the Auxiliary Building Secondary Containment Enclosure may be unisolated under administrative controls.

SEQUOYAH - UNIT 2 314 9-5 Amendment No. 199, 240, 251, 278

3/4.9 REFUELING OPERATIONS BASES 3/4.9.1 BORON CONCENTRATION The limitations on reactivity conditions during REFUELING ensure that: 1) the reactor will remain subcritical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel. Maintaining the listed valves In the closed position precludes an uncontrolled boron dilution accident by closing the flow paths for possible sources of unborated water. These limitations are consistent with the initial conditions assumed for the boron dilution incident in the accident analyses.

3/4.9.2 INSTRUMENTATION The OPERABILITY of the source range neutron flux monitors ensures that redundant monitoring capability Is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of Irradiated fuel assemblies in the reactor pressure vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay time Is consistent with the assumptions used in the accident analyses.

3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment building penetration closure and OPERABILITY ensure that a significant release of radioactive material within containment will be restricted from leakage to the environment. The OPERABILITY and closure restrictions are sufficient to restrict radioactive material release from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING MODE. Containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side during movement of irradiated fuel. The containment building equipment door must be closed during movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />). 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 containment penetrations during fuel movements. Both sets of the containment personnel airlock doors may be open during movement of Irradiated fuel in containment provided one train of Auxiliary Building Gas Treatment System (ABGTS) is available for manual operation. The basis of this is that SQN is analyzed for a fuel handling accident (FHA) in either the containment or the auxiliary building; however, a manual ABGTS start may be necessary for a containment FHA. The requirement for an airlock door to be capable of closure is provided to allow for long-term recovery from a FHA in containment.

During movement of irradiated fuel assemblies, a single normal or contingency method to promptly close the containment building equipment door will be in place. Such prompt methods need 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.

The LCO Is modified by a footnote allowing penetration flow paths with direct access from the containment atmosphere to the Auxiliary Building Secondary Containment Enclosure (ABSCE) to be unisolated under administrative controls. These flow paths must be within the ABSCE structure or in qualified piping that constitutes the ABSCE boundary and either terminate or have an isolation device within the ABSCE. Administrative controls ensure that 1) appropriate personnel are aware of the open status of the penetration flow path during movement of irradiated fuel assemblies within containment, 2) specified individuals are designated and readily available to isolate the flow path in the event of an FHA, and 3) one train of the ABGTS is OPERABLE In accordance with Technical Specification 3.9.12. As discussed above for the containment airlock doors, the basis for this allowance Is the SQN analysis for an FHA in containment or the auxiliary building and the potential need for a manual start of the ABGTS for an FHA in containment This allowance is not applicable to the containment ventilation isolation flow paths because of the potential motive force associated with the containment purge system that could result In additional releases of radioactivity. Additionally, this allowance is not applicable to those flow paths that terminate or are routed outside the ABSCE in piping that does not meet the requirements for an ABSCE boundary.

SEQUOYAH - UNIT 2 B 3/4 9-1 Amendment No. 199, 240, 251, 278