ML033160331

,Kewaunee & Hatch Meeting Handout Re Planned License Amendment Requests Using Alternate Source Term

ML033160331
Person / Time
Site:	Hatch, Kewaunee
Issue date:	11/06/2003
From:	Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML033160331 (31)

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. I I sNMC Committed to Nuclear Excellence

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Kewaunee Equipment Hatch License Amendment Request

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F Agenda a Objectives

-* Reason For Change

• Overview of System

• Specific TS Changes

• ISTS Differences

• Justification Overview

• Timeline N a e Commlhed to Nudear Ecgrc

- I November 6, 2003 2

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• Obtain common understanding of LAR for KNPP

• Determine Potential Roadblocks

• Discuss Timeline for LAR

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No Reasons For Change

• Refuel while Equipment Hatch Open m Flexibility in Outage Schedule

• Add Requirements for CR Post Accident Recirculation System to Support Analysis vCmobmerfed to 203ea E 5

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-ELEVATION 657' REACTOR & SHIELD BLDG EXHAUST ELEVAT ION 773' 11' AUX. BLDG. VEIIT SYSTEM ITAKE EL. 6r4aG" ALTERNATE CR INTAKE OFFICE/WARE IIOUSE AVJVE%

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Item Description 1

Beam 2

Stop 3 & 4 Trolley 5

Pivot Point 6

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Jactuator 8 & 9 Sliding Points 10 Alignment Lug A

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N Technical Specification Changes

- Equipment Hatch Open during Fuel Handling

• Hatch and Airlocks open during head and internals lift

• 24 Hours with Both CRPAR trainsQO

• Verification of capability to close hatc S

every 7 days NMC CommiMed to Nudear Excefenc W

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Differences from ISTS X Four bolts to hold equipment hatch CRPARS Operable in Modes 3 & 4 5&6]

i End State with CRPARS OOS (Mode 5)

E Toxic Chemical Mode of Operation E Two CRPARS Trains OOS (non,-

Boundary) enter 3.0.3 D Positive Pressure in Control, Rom Comnmitted to Nucear Eceflence November 6, 2003 18

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L Justification Overview

. Based on ISTS n 3.9.4 Containment Penetrations 3.7.10 Control Room Emergency Filtration System (CREFS)

TSTF 441, Equipment Hatch m Acceptable Results from Analysis without containment structure credit I..

P Limit Analysis Location (TEDE)

Results

_ _ _ _ _ _ _ _ _ _ _ _(T E D E )

Site Boundary 6.3 rem 0.7 rem Low Population Zone 6.3 rem 0.11 rem Control Room 5.0 rem 1.0 rem November 6, 2003 Cornmftted to Nuclear EzveHenc 19

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• Provide Schedule by 12/5/03 of

• ASTM E741 Test & Results vs Assumption

• In-Leakage in Hazardous Chemical Analysis Smoke Assessment

. TS Changes November 6, 2003 Commfted to Nuclear Exw ene 20

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Timeline

- Submittal Date m Approval

- June 30, 2004

. Refueling Outage Fall 2004 November 6,, 2003 No Committed to Nudear E xcee nc t 21

3.8 REFUELING OPERATIONS APPLICABILITY Applies to operating limitations during REFUELING OPERATIONS.

OBJECTIVE To ensure that no incident occurs dui public health and safety.

REFUELING OPERATIONS that would affect irs prior to movement of its irradiated fuel all be continuously monitored by at least is ual indication in the control room and qnjint whenever core geometry is being bing changed at least one neutron flux When there is fuel in reactor, a4inimum boron concentration as specified in the COLR shall be maintaine the eactor Coolant System during reactor vessel head removal or while loading and~ loading fuel from the reactor. The required boron concentration shall be verified by chemical analysis daily.

(1) Administrative controls ensure that:

• Appropriate personnel are aware that the equipment hatch or both personnel air lock doors are open,

• A specified individual(s) is designated and available to close the equipment hatch and air lock following a required evacuation of containment, and

• Any obstruction(s) (e.g., cables and hoses) that could prevent closure of an open air lock can be quickly removed.

Amendment No. xxx TS 3.8-1 xx/xx/2004

BASIS - Refueling Operations (TS 3.8)

The equipment and general procedures to be utilized during REFUELING OPERATIONS are discussed in the USAR. Detailed instructions, the above specified precautions, and the design of the fuel handling equipment incorporating built-in interlocks and safety features, provide assurance that no incident occurs during the REFUELING OPERATIONS that would result in a hazard to public health and safety.(') Whenever changes are not being made in core geometry, one flux monitor is sufficient. This permits maintenance of the instrumentation. Continuous monitoring of radiation levels (TS 3.8.a.2) and neutron flux provides immediate in cation of an unsafe condition. The residual heat removal pump is used to maintain a uniform brd-concentration.

Containment Closure (TS 3.8.a.1)

During movement of recently irradiated fuelassembj than 30 days) within containment, a release ffissio containment will be restricted from escaping the e requirements are met. When above COLD SHU Ov\\

maintaining containment OPERABLE as describe ir SHUTDOWN, the potential for containment press riz likely; therefore, requirements to isolate the contal can be less stringent. The TS requireme err rather than "containment OPERABILI

." Containme escape paths are closed or capable being closed.

containment pressurization, the App ndix J a

e The containment serves to cinta fis ion rdt n

from the reactor core foil an agcist, su h the maine I

ithin (e retirements of 10 FR 5 py vides radiat hisn from t e fission Ioduc dontainment atmosp ere allowing acident c ditic decayed less within TS Kby COLD acc ntM not in the

,he contaigbnent pressure boundary, cbmpons into and out of Wd fuel assemblies within containment,

ed or held in place by at least four at the bolts required by this TS be The contain nt air logs, hich are Iso part of the containment pressure boundary, provide a mea or perss nel accesX during operation above COLD SHUTDOWN in accordance with S 3.6.a, "Containm nt System Integrity". Each air lock has a door at both ends. The doo are normally' terlocked to prevent simultaneous opening when CONTAINMENT INTE ITY is re ired. During periods of unit shutdown when containment closure is t refired, the door interlock mechanism may be disabled, allowing both doors of anlock to remain open for 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

') USAR Section 9.5.2 Amcndmcnt No 165 I 03/444203 TS B3.8-1

mechanism may remain disabled, but one air lock door must always remain closed or capable of being closed.

The requirements for containment penetration closure provides additional defense-in-depth to further ensure that a release of fission product radioactivity within containment will be restricted to within regulatory limits.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, oy a manual isolation valve, blind flange, or equivalent. Equivalent isolation thod mu be aproved and may include use of a material that can provide a t por ry, tmosp c ressure, ventilation barrier for the other containment penetratiots dunecrin c

y irradiate uel movements.

During REFUELING OPERATIONS or move nt of ir di d fuel asse lies within containment, the most severe radiological co equen s It from a f I handling accident involving handling recently irradiated el. The fuel g acci nt is a postulated event that involves damage to rradia d fuel. Fuel ndli accid ts, analyzed include dropping a single irradiated fue ssembly agd handli tool a

vy object onto other irradiated fuel assemblies al ods in one ssembl re damage releasing the gap activity of odines and oble ga s) require ents offS 3.8.a.10, refueling cavity water level, in conjun Iion with a miumecayti of 100 urs prio to irradiated fuel movement with co ainment osure cabi or a meimum d ie of 30 days without containment closre capailit ensur that e relea of fission product radioactivity, subse to fuel h ndl g accide ress in do s that are within the values specified i 10 C R

.6 difie by Re lato Guide.183, Alternative Radiological e Tsrms r Eval ating ign Ba Ac es at Nuclear Pot Reac (RG 4183).

e a ptance mits fr oite ra on exposure for a F uzel Handling Ac entk listed in G 1.183 a 6.3 re TE E, which 25% of the 10 CFR 0.67 limits. Contain nt netratio s satisfy riterion f 10 0.36(c)(2)(ii).

This TS s

conseqnc of a fu handlin ccident I olving handling recently irradiate uel in ctainmenby iting t potentia paths for fission product r ioactivit releasevithin ctai ent.

TS requires any penetration providing dire access om the ntainm t at ospher to the outside atmosphere to be closed, have OPERABLE automatic isoltion,r, as in e case of the containment personnel air~~

lc equit hat

, capae of osed.

The TS is mo fied allo in penetrati n flow paths with direct access from the containment at osphere o the outside atmosphere to be unisolated under administrative controls. Adminis ative controls en re that 1) appropriate personnel are aware of the open status of the p etration flow ath during REFUELING OPERATIONS or movement of irradiated fuel asse lies wit n containment, and 2) specified individuals are designated and readily a ila e to isolate the flow path in the event of a fuel handling accident.

The containment personnel air lock doors many be open during movement of irradiated fuel in the containment and during REFUELING OPERATIONS provided that one door is capable of being closed in the event of a fuel handling accident. Should a fuel handling Amcndment Noa 165 TS B3.8-2 03/14/ 203 l

accident occur inside containment, one personnel air lock door will be closed following an evacuation of containment.

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. When above COLD SHUTDOWN, containment penetration requirements are addressed by TS 3.6. In COLD SHUTDOWN or REFUELING, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist.

dditionally, due to radioactive decay, a fuel handling accident involving handling receitI rradiated fuel (i.e., fuel that has occupied part of a critical reactor core withi he pr vio 30 days) will result in doses that are well within the guideline value specfie in 10 67 even without containment closure capability. Therefore, nder thee nditions no quirements are placed on containment penetration status.

If the containment equipment hatch, air locks r any t

ent pene tion that provides direct access from the containment at osphere to o side at osphere is not in the required status, including the Contain nt Purge an xh ust Iso ion System not capable of automatic actuation when the pur and exha t valve re ope unit must be placed In a condition where the isol ion f ction is n needed

.his is accomplished by immediately suspendi move ntcently i adiated el assemblies within containment. Perfo ance of the actis shall ot preci e

completion of movement of a compo ent to a safe pos n.

A minimum shutdown margin o art quIto 5 Ak/Stb aintain in the core.

The boron concentration a cified t

OL is suffcnt to en re a d uate margin of safe

.e cificatio or REU ELI OPERION shu own m n is ased on a dilution d ing refueling a dent)

With an nitial shut own m frgin 5% Ak/k nder the postulated

,ccident conditions, itill ta longer t an 30 mintes for act o crtical. This is ample time for the operator to re gni the au le high co nt rate signal, d isolate the reactor makeup watersys odic che o

fueling aterboro oncentratia ensure that proper shutdown margin i maintai

d. Spec cat n 3.8.a.

oallows th room operator to inform the anipulato operator f any im ndi unsafe ondition detected from the main control board Interlocs are utili d dunREFU ING ERA ONS to ensure safe handling. Only one assembly a time c be ha died. T e fuel h ing hoist is dead weight tested prior to use to assure prope crane op tion It will not e possible to lift or carry heavy objects over the spent fuel pool when fuel stored thin through nterlocks and administrative procedures. Placement of additional spent I racks will be controlled by detailed procedures to prevent traverse directly above spent fuel.\\

The one hundred forty-et hour ecay time following plant shutdown is consistent with the spent fuel pool cooling analysis a o bounds the assumption used in the dose calculation for the fuel handling accident. The requirement for the spent fuel pool sweep system, including charcoal adsorbers, to be operating when spent fuel movement is being made provides added assurance that the off-site doses will be within acceptable limits in the event of a fuel handling accident. The spent fuel pool sweep system is designed to sweep the atmosphere above the refueling pool and release (2) USAR Section 14.1 Amcndmcnt O. 165 TS B3.8-3 024412003

3.12 CONTROL ROOM POST-ACCIDENT RECIRCULATION SYSTEM APPLICABILITY Applies to the OPERABILITY of the Control Room Post-Accident Recirculation System.

OBJECTIVE To specify OPERABILITY requirements the Control Room Post-Accident Recirculation System.

SPECIFICATION

a. The reactor shall not be make critica nles he followin conditions are satisfied,

1. unless bthTwo trains of Cnro A

ident tn System are OPERABLE, except as pro ed by TS 3.12.

2. During power operation or re very from anadverte p, the follow ng conditions of inoperability may est during the m interv pecifie.

If OPERABILITY is not rest in e

e speciR d, then wi hour action shall be initiated\\

Achieve HOT STA DBY wii e next urs.

Achieve HOT SHU OWN ithi the followinhou A. One train of Ct-Accecicu may be out of service for s.

B. Two trai s of Contro Room Pos Accident Recir ulation may be out of s

e for hours if e to contro oom bound ry failure.

1. Botw tr ins of the ntxro oo P t-Accent Recircution Systemg filters, shll OPERA

,exe ov d by shut d wthi n4 hours, except that h

2 ROGnidee inofoIR Post-A cid Rirculatio ystem yd b e of A.r ~ The opposte train is In vicein the emergency mode ot u

M L n ERA of fuel assemblies that have piinapa criti act evious 30 days:

1. Tw~ins of t ntr Room Po~sit-Accident Recirculation System shall be xcept Sovided by 3.12.b.2 and TS 3.12.b.3.

2. One train o o

Room Post-A fident Recirculation System may be out of service provided:

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A. The opposite trai isi/

e in the emergency mode or, B. Movement of fuel assemblies that have occupied part of a critical reactor within the previous 30 days is suspended.

ARmendmest rNe.

s5 l TS 3.12-1 Q2Lq8Lq0014l

3. Two trains of Control Room Post-Accident Recirculation System may be out of service provided movement of fuel assemblies that have occupied part of a critical reactor within the previous 30 days is suspended.

c. During testing the system shall meet the following performance requirements:

1. The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filter and charcoal adsorber banks shall show 2 99% DOP removal and 2 99% halogenated hydrocae~*Q removal.

2. The results of the laboratory Post-Accident Recirculati9 iodide removal when te ed in,

301C, and 95% RH.

3. Fans shall operate within

d. The control room boundary may control.

lysis from the Control Room

+2K 95% radioactive methyl TM/D3803-89 at conditions of

,Amcndmcnt No. 154 02/28/20041 TS 3.12-2

BASIS - Control Room Post-Accident Recirculation System (TS 3.12)

The Control Room Post-Accident Recirculation System (CRPARS) is designed to filter the Control Room atmosphere during Control Room isolation conditions. The Control Room Post-Accident Recirculation System is designed to automatically start upon SIS or high radiation signal. The CRPARS consists of two independent, redundant trains that recirculate and filter the control room air. Each train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section, for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, and inst nttion also form part of the system.

If the ytem o foeund t be inapeabmi a

er fl di bias the atrol Room atd ieantTo spefatin may antinue dfmt a limiteo co l r I the system taent o elrge athi7 dacte rele a.

Te C R

is thcne dOPER e mthe The CRPARS satisfies Criterion 3 o0 CFR (2)(i) for deor o

e basis accidents and fuelhandlingaccidents.\\

Two independent and redundant trai s

are req ure that at least one is available assu n

failure di rain. Total system failure could result in exc a o o 5 rem tc r

in oerato in the event of a large radioactive release. The r consi d OPERn the individual components necessary to a r P

re are i crABLE in both trains./\\

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A CRPARS train is OPERABLE wherte ast ed: ait

a. Fan is OPERABLE

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b. HEPA filters nd roal rivers otnotl modivesticting flow, and arpers)e cring of e

g t Fr 0trat ouncin and C.soiBelve ampenn OP incinulation can be

/maintained.

In adtion, the c ThIs room o

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e m ined, including the ntegrity of the whes, floo

clIngs, ork, andrs.

Ang the control room boundary to openr enxitently u r a folo aBA.l I aodifies the TS. For entry and exit th o coors,> a rease frotre tre of a gIng is performed by the person Ta ring or e g th reire o openings, these controls consist of stationing cluioated indiial at fopenin ho is in continuous communication with he c wn This insdue tIll have method to rapidly close the opening when a ne icued o chnilm ifatn is indicetfd.

When CRITICAL and during RuELING OPEI {AmION, CRPARS must be OPERABLE to control operator exposure during ollo a DBA. In all Modes, the CRPARS is required to cope with a release from tpueof a gas decay tank (GDT) or the Volume Control Tank (VCT). Although required o cope with a release from the gas decay tank or the Volume Control Tank the requirement does not meet the criteria found in 1 0 CFR 50.36 for inclusion in Technical Specifications, therefore the requirement for operability of the CRPARS when in all modes due to the presents of radioactive gases in the GDT or VCT is not included in the Technical Specifications. During-movement of recently Amcendmeist N.

5P TS B3.12-14 (2/28Q404

irradiated fuel assemblies, the CRPARS must be OPERABLE to cope with the release from a fuel handling accident [involving handling recently irradiated fuel]. [The CRPARS 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 [ ] days), due to radioactive decay.]

When one CRPARS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CRPARS train is adequate to perform the control room protection functio owever, the overall reliability is reduced because a single failure in the OPERABLE C PA train could result in loss of CRPARS function. The 7 day Completion Time is based\\on the p

ability of a DBA occurring during this time period, and ability of eima ing train to pro e the required capability.

If the control room boundary is inop able w1n I, the CRPAR ains cannot perform their intended functions. Actios must be tak ore an 0 1 control room boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During t eriod that th cont oom boundary inoperable, appropriate compensatory meas res (consisnt with th tent of GDC

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should be utilized to protect control room op ators from potial haza such as radioactive contamination, toxic chemicals sm peratured relative

ity, and physical security. Preplanned mea res be aliable to dress these concerns for Intentional and unintenti nal entry intone con on. The hour Completion Time is reasonable bas on thejl w proba ty of a UBA occu*ng during this time period, and the use of com nsat masures. Th 4 ho Coinletion time is a typically reasonable time to diagnie, plaand possbly repai d temost problems with the control room bounda When critical, if the noperab RPA train or ontro 00 bo cannot be restored to OPERABLE sta s in t e require Comple n Tim the unit must be placed in a MODE that m i zes accilnt risk. To hieve this st us, the unit must be placed i lat H

W N withi 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

llowed ompletion Time is reason le, baseon n opng

erience, reach the r d unit conditions from full poer conditions in an or m

er and hout challenging unit systems.

Ding REFUE

TIONS, able CRS train cannot be restored to OP BLE stat within the equired Co pleti Timection must be taken to immedi y place th PERABL CRPARS ain emergency mode. This action ensures tha e remaini train is ERABL that no failures preventing automatic actuation will our, and tha ny acti e failure ould be readily detected. An alternative is to immediately s end activiis t at could r suit in a release of radioactivity that might require isolation he contro room. Thi places the unit in a condition that minimizes risk. This does nreclude the mo ement of fuel to a safe position.

During REFUELING OPERATIONS th tw RPARS trains inoperable, action must be taken Immediately to suspend activitie t 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.

If both CRPARS trains are inoperable when critical for reasons other than an inoperable control room boundary, the CRPARS may not be capable of performing the intended Amendment No. 52 TS B3.12 0/28/2001-l

function and the unit is in a condition outside the accident analyses. Therefore, a plant shutdown as stated in TS 3.12.a.2 must be initiated.

Accident analysis assumes a charcoal adsorber efficiency of 90%.(I) To ensure the charcoal adsorbers maintain that efficiency throughout the operating cycle, a safety factor of 2 is used.

Therefore, if accident analysis assumes a charcoal adsorber efficiency of 90%, this equates to a methyl iodide penetration of 10%. If a safety factor of 2 is assumed, the methyl iodide penetration is reduced to 5%. Thus, the acceptance criteria of 95% efficient will be used for the charcoal adsorbers.

K Although committing to ASTM D3803-89, it o references Military Standards MIL-F-51 06 Fil MIL-F-51079A, Filter, Medium Fire Re 'stant revised and the latest revisions are, MIl F-51 06E canceled and superseded by ASME A 1, Code an acceptable substitution. Consequent other standard or methodology is shown to p i

referenced in ASTM D3803-89.

ASTM D3803-89 Standard Zfficiency, Fire Resistant, and Ospecifications have been These revisions have been as Wtment. ASME AG-1 is 3 can be' 94bstit d if the new sdor erfo ce those I

(') USAR TABLE 14.3-8, "Major Assumptions for Design Basis LOCA Analysis" Amcndmcnt No. 152 TS B3.12-34 -28/2001

b. Prior to entering INTERMEDIATE SHUTDOWN from COLD SHUTDOWN, if not performed in the previous 92 days, yereach containment isolation manual valve and blind flange that Is located in Id containment and required to be closed during accident conditions is clo ed, e ep containment isolation valves that are locked sealed or ise ecured fosed open as allowed by TS 3.6.b.2.

c. Valves and blind flanges in high rad tion eas may be ified by use of adminisrative means.

g. During REFUELING OPERATIONS Wih capability to close the equipment hatch.

Amendment No. xxx 2004 TS 4.4-4