ML072200451
| ML072200451 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/03/2007 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3351, LAR 06-003 | |
| Download: ML072200451 (15) | |
Text
FENOC "EW-%
5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 Mark B. Bezilla 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 Docket Number 50-346 10 CFR 50.90 License Number NPF-3 Serial Number 3351 August 3, 2007 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555-0001
Subject:
Davis-Besse Nuclear Power Station Improved Technical Specification Conversion (License Amendment Request No. 06-0003)
Ladies and Gentlemen:
Pursuant to 10 CFR 50.90, the FirstEnergy Nuclear Operation Co. (FENOC) hereby requests amendment of the Operating License (NPF-3) for the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS). FENOC proposes to revise the current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) consistent with Improved Standard Technical Specifications (ISTS) as described in NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants," Revision 3.1, and certain generic changes to the NUREG. The guidance of NEI 96-06, "Improved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC) Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," dated October 9, 1996, were used in preparing this submittal. The detailed descriptions and justifications to support the proposed changes are provided in the volumes attached to this letter (Attachment 1).
The following enclosures are also included to assist the NRC in the review of this submittal:, "Contents of the Davis-Besse Nuclear Power Station Improved Technical Specifications (ITS) Submittal," describes the organization and content of the submittal, including each of the volumes in Attachment 1., "Beyond Scope Changes," provides a list and description of the changes included in the ITS submittal that are beyond the scope of the ISTS as described in NUREG 1430, Revision 3.1, and also beyond the scope of the CTS.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 2, "Disposition of Generic Changes to NUREG-1430, Revision 3.1," lists the NRC approved changes to NUREG-1430, Revision 3.1, as of June 30, 2007, and summarizes the disposition of each of these changes in the Davis-Besse Nuclear Power Station license amendment request. The enclosure also lists other generic changes approved for use by the industry but not approved by the NRC (i.e., "T" travelers)., "Disposition of Existing License Amendment Requests," provides the disposition of other, currently docketed license amendment requests, as they relate to this license amendment request.
Approval of the proposed license amendment is requested by August 1, 2008, to support implementation of the ITS by the desired date of December 1, 2008. FENOC requests an implementation period of at least 180 days to accommodate potential delay in completion of implementation activities. FENOC will notify the NRC when ITS implementation actions are completed.
The commitments contained in this letter are listed in Attachment 2.
If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager-FENOC Fleet Licensing, at (330) 761-6071.
The statements contained in this submittal, including its associated attachments and enclosures, are true and correct to the best of my knowledge and belief. I am authorized by the FirstEnergy Nuclear Operating Company to make this submittal. I declare under penalty of perjury that the foregoing is true and correct.
Executed on 41!
Li&
Go ark B. Bezilla, Vice resident-Nuclear MKL
Enclosures:
- 1. Contents of the Davis-Besse Nuclear Power Station (DBNPS) Improved Technical Specifications (ITS) Submittal
- 2. Beyond Scope Changes
- 3. Disposition of Generic Changes to NUREG-1430, Revision 3.1
- 4. Disposition of Existing License Amendment Requests Attachments: 1. ITS Submittal, Volumes I through 17
- 2. Commitment List
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 3 cc:
(all w/o Attachment 1)
Regional Administrator, NRC Region III NRC/NRR Project Manager NRC Region III, DB-1 Senior Resident Inspector Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Enclosure I Page 1 of 6 CONTENTS OF THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL of the submittal for the conversion of the current Technical Specifications (CTS) to the ITS for the DBNPS consists of the following seventeen volumes:
Volume Title I
Application of Selection Criteria to the Davis-Besse Nuclear Power Station Technical Specifications 2
Generic Determination of No Significant Hazards Considerations and Environmental Assessment 3
ITS Chapter 1.0, Use and Application 4
ITS Chapter 2.0, Safety Limits 5
ITS Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability 6
ITS Section 3.1, Reactivity Control Systems 7
ITS Section 3.2, Power Distribution Limits 8
ITS Section 3.3, Instrumentation 9
ITS Section 3.4, Reactor Coolant System 10 ITS Section 3.5, Emergency Core Cooling Systems (ECCS) 11 ITS Section 3.6, Containment Systems 12 ITS Section 3.7, Plant Systems 13 ITS Section 3.8, Electrical Power Systems 14 ITS Section 3.9, Refueling Operations 15 ITS Chapter 4.0, Design Features 16 ITS Chapter 5.0, Administrative Controls 17 CTS Markup Pages in CTS Order Volumes I and 17 are provided to assist the Nuclear Regulatory Commission (NRC) in the review and approval of Volumes 2 through 16. Below is a brief description of the content of each of the volumes in this submittal.
Volume 1 Volume I provides details concerning the application of the selection criteria to the individual DBNPS CTS. Each CTS Specification is evaluated, and a determination is made as to whether or not the CTS Specification meets the criteria in 10 CFR 50.36(c)(2)(ii) for retention in the proposed ITS.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Enclosure I Page 2 of 6 CONTENTS OF THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL Volume 2 Volume 2 contains the majority of the evaluations required by 10 CFR 50.91(a), which support a finding of No Significant Hazards Consideration (NSHC). Based on the inherent similarities in the NSHC evaluations, generic evaluations for a finding of NSHC have been written for the following categories of CTS changes:
Administrative Changes More Restrictive Changes Relocated Specifications Removed Detail Changes Less Restrictive Changes -
Category 1 - Relaxation of LCO Requirement Less Restrictive Changes -
Category 2 - Relaxation of Applicability Less Restrictive Changes -
Category 3 - Relaxation of Completion Time Less Restrictive Changes -
Category 4 - Relaxation of Required Action Less Restrictive Changes -
Category 5 - Deletion of Surveillance Requirement Less Restrictive Changes -
Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria Less Restrictive Changes -
Category 7 - Relaxation of Surveillance Frequency, Non-24 Month Type Change Less Restrictive Changes -
Category 8 - Deletion of Reporting Requirements Less Restrictive Changes -
Category 9 - Addition of LCO 3.0.4 Exception Less Restrictive Changes -
Category 10 - Deletion of Surveillance Requirement Shutdown Performance Requirements For those less restrictive changes that do not fall into one of the generic Less Restrictive Changes categories, specific NSHC evaluations have been performed and are provided in the applicable Chapter, Section, or Specification in Volumes 3 through 16.
In addition, Volume 2 contains an evaluation of environmental consideration in accordance with 10 CFR 51.21. It has been determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), and no environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 3 of 6 CONTENTS OF THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL Volumes 3 through 16 Volumes 3 through 16 provide the details and safety analyses to support the proposed changes.
Each of these volumes corresponds to a Chapter, Section, or Specification of NUREG-1430, Revision 3.1. Each volume contains the required information to review the conversion to ITS, and includes the following:
" Individual ITS Specifications in ITS Chapter (Volumes 3, 4, and 15), Section (Volume 5), or Specification (Volumes 6 through 14 and 16) order;
" Relocated/Deleted CTS Specifications (if applicable); and
" ISTS Specifications not adopted in the DBNPS ITS (if applicable).
The information for each of the above three types of specifications is organized as follows:
CTS Markup and Discussion of Changes (DOCs) (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)
This section contains a markup of the CTS pages, either for CTS pages associated with an Individual ITS Specification or for Relocated/Deleted CTS Specifications, and the DOCs from the CTS. CTS license amendment requests under NRC review that have been docketed as of July 31, 2007 have been incorporated in the proposed changes as described in of this submittal.
The CTS markup pages for each ITS Specification are normally in numerical order.
However, more than one CTS Specification is sometimes used in the generation of an ITS Specification. In this case, the CTS pages that are the major contributor to the ITS Specification are shown first, followed by the remaining associated CTS pages in numerical order.
The left-hand margin of the CTS markup pages includes a cross-reference to the equivalent ITS requirement. The upper right-hand comer of the CTS markup pages is annotated with the ITS Specification number to which it applies. Items on the CTS markup pages that are addressed in other proposed ITS Chapters, Sections, or Specifications are annotated with a reference to the appropriate ITS Chapter, Section, or Specification.
The CTS markup pages are annotated with an alphanumeric designator to identify the differences between the CTS and the proposed ITS. The designator corresponds to a DOC, which provides the description and justification of the change. The DOCs are located directly following the associated CTS markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 and 16).
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Enclosure I Page 4 of 6 CONTENTS OF THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL Each proposed change to the CTS is classified into one of the following categories:
Designator Category A
ADMINISTRATIVE CHANGES -
Changes to the CTS that do not result in new requirements or change operational restrictions or flexibility.
These changes are supported in aggregate by a single generic NSHC.
M MORE RESTRICTIVE CHANGES -
Changes to the CTS that result in added restrictions or reduced flexibility. These changes are supported in aggregate by a single generic NSHC.
R RELOCATED SPECIFICATIONS -
Changes to the CTS that relocate specifications that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii). These changes are supported in aggregate by a single generic NSHC.
LA REMOVED DETAIL CHANGES -
Changes to the CTS that eliminate detail and relocate the detail to a licensee-controlled document. Typically, this involves details of system design and function, or procedural detail on methods of conducting a Surveillance Requirement. These changes are supported in aggregate by a single generic NSHC. In addition, the generic type of removed detail change is identified in italics at the beginning of the DOC.
L LESS RESTRICTIVE CHANGES -
Changes to the CTS that result in reduced restrictions or added flexibility. These changes are supported either in aggregate by a generic NSHC that addresses a particular category of less restrictive change, or by a specific NSHC if the change does not fall into one of the ten categories of less restrictive changes. If the less restrictive change is covered by a generic NSHC, the category of the change is identified in italics at the beginning of the DOC.
The DOCs are numbered sequentially within each letter designator for each ITS Chapter, Section, or Specification.
The CTS Bases pages are replaced in their entirety by the proposed DBNPS ITS Bases, and markup pages are not provided in the ITS submittal.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 5 of 6 CONTENTS OF TIlE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL ISTS Markup and Justification for Deviations (JFDs) (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the DBNPS ITS)
This section contains a markup of the NUREG-1430, Revision 3.1, ISTS pages, either for ISTS pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the DBNPS ITS, and JFDs from the ISTS. The ISTS pages are annotated with a numeric designator to identify the differences between the ISTS and the proposed ITS. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 and 16). The ISTS markup pages are also annotated to show the incorporation of NRC-approved generic changes (Technical Specification Task Force (TSTF) change travelers) that are applicable to the DBNPS ITS.
The left-hand margin of the ISTS markup pages includes a cross-reference to the equivalent CTS requirement.
ISTS Bases Markup and JFDs (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the DBNPS ITS)
This section contains a markup of the NUREG-1430, Revision 3.1, ISTS Bases pages, either for ISTS Bases pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the DBNPS, and JFDs from the ISTS Bases. The ISTS Bases pages are annotated with a numeric designator to identify the differences between the ISTS Bases and the proposed ITS Bases. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS Bases markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 and 16). The ISTS Bases markup pages are also annotated to show the incorporation of NRC-approved generic changes (TSTF change travelers) that are applicable to the DBNPS ITS Bases. The volumes for ITS Chapters 1.0, 4.0, and 5.0 do not include this section, because NUREG-1430, Revision 3.1, does not include any Bases for these Chapters.
Determination of NSHC (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)
This section contains the determination in accordance with 10 CFR 50.91(a)(1) using the criteria of 10 CFR 50.92(c) to support a finding of NSHC. For those changes
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Enclosure I Page 6 of 6 CONTENTS OF THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL covered by a generic NSHC, those generic NSHCs are located in Volume 2. For those less restrictive changes that do not fall into one of the generic less restrictive categories, a specific NSHC evaluation has been performed. Each evaluation is annotated to correspond to the DOC discussed in the NSHC. For those ITS Chapters, Sections, or Specifications for which the less restrictive DOCs all fall into a generic category, a statement that there are no specific NSHCs is provided.
Volume 17 Volume 17 contains copies (from Volumes 3 through 16) of the DBNPS CTS markup pages that have been annotated to show the differences between the CTS and the proposed ITS. This volume is organized in CTS page order, and has been prepared to facilitate NRC review efforts.
They also demonstrate that all CTS requirements have been appropriately dispositioned. In some instances, the same CTS page is used in different ITS Chapters, Sections, or Specifications.
Consequently, the CTS markup pages that are included in more than one ITS Chapter, Section, or Specification will appear in the order in which the CTS markup pages appear in Volumes 3 through 16.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page I of 2 BEYOND SCOPE CHANGES Beyond Scope Changes are those changes included in the Improved Technical Specifications (ITS) conversion submittal that are beyond the scope of the Improved Standard Technical Specifications (ISTS) as described in NUREG-1430, Revision 3.1, and also beyond the scope of the Davis-Besse Nuclear Power Station (DBNPS) current Technical Specifications (CTS). The following is a list of the discussions of changes (DOCs) in Attachment I that are Beyond Scope Changes in the DBNPS ITS conversion submittal.
- 1)
ITS 3.3.8, DOC L03: CTS 4.3-2 Functional Unit 4.b requires a CHANNEL CHECK of the Essential Bus Feeder Breaker Trip Degraded Voltage Relay (DVR). CTS 4.3-2 Functional Unit 4.c requires a CHANNEL CHECK of the Diesel Generator Start and Load Shed on Essential Bus, Loss of Voltage Relay (LVR). ITS 3.3.8 does not require a CHANNEL CHECK. This changes the CTS by not requiring a CHANNEL CHECK of the two relays.
- 2)
ITS 3.3.11, DOC M02: CTS Table 3.3-12 Functional Unit 1, Steam Line Pressure-Low, specifies an Allowable Value of> 591.6 psig for the CHANNEL FUNCTIONAL TEST and > 586.6 psig for the CHANNEL CALIBRATION. CTS Table 3.3-12 Functional Unit 2, Steam Generator Level-Low, specifies an Allowable Value of> 16.9 inches for the CHANNEL FUNCTIONAL TEST. CTS Table 3.3-12 Functional Unit 3, Steam Generator Feedwater Differential Pressure-High, specifies an Allowable Value of
< 197.6 psid for the CHANNEL FUNCTIONAL TEST and 5 199.6 psid for the CHANNEL CALIBRATION. ITS Table 3.3.11-1 Functions 1, 3, and 2 specify Allowable Values of> 600.2 psig, > 17.3 inches, and < 176.8 psid, respectively. This changes the CTS by changing the Allowable Values for these three Functional Units.
- 3)
ITS 3.4.1, DOC M01: CTS 3.2.5 requires that departure from nucleate boiling (DNB) parameters specified in CTS Table 3.2-2, including reactor coolant pressure, be maintained within specified limits. CTS Table 3.2-2 requires the measured reactor coolant system pressure to be > 2062.7 psig for four reactor coolant pump operation and
> 2058.7 psig for three reactor coolant pump operation. ITS LCO 3.4.1.a requires Reactor Coolant System (RCS) loop pressure be > 2064.8 psig for four reactor coolant pump operation and ITS LCO 3.4.1.b requires RCS loop pressure be > 2060.8 psig for three reactor coolant pump operation. These values are also provided in ITS SR 3.4.1.1.
This changes the CTS by increasing the DNB reactor coolant pressure parameter limits.
- 4)
ITS 3.4.4, DOC LOI: CTS 3.4.1.1 Action a, which applies when shifting from four reactor coolant pumps (RCPs) operating to three RCPs operating, requires a reduction of the High Flux trip setpoint from the four RCPs operating to three RCPs operating trip setpoint within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Under the same conditions, ITS 3.4.4 ACTION A requires the reduction in the trip setpoints within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. This changes the CTS by extending the Completion Time to reduce the trip setpoints from "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />" to "10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />."
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 2 of 2 BEYOND SCOPE CHANGES
- 5)
ITS 3.5.1, DOC LO1: CTS LCO 3.5.1.b requires each core flooding tank (CFT) contained water volume be between 7555 gallons and 8004 gallons of borated water.
CTS LCO 3.5.1.d requires each CFT nitrogen cover pressure be between 575 psig and 625 psig. In the ITS, the CFT borated water volume is specified in ITS SR 3.5.1.2 and the CFT nitrogen cover pressure is specified in ITS SR 3.5.1.3. ITS SR 3.5.1.2 requires the borated water volume in each CFT to be > 7480 gallons and < 8078 gallons and ITS SR 3.5.1.3 requires the nitrogen cover pressure in each CFT to be > 567 psig and
< 633 psig. This changes the CTS by allowing a wider range for the CFT borated water volume and nitrogen cover pressure.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 1 of 2 DISPOSITION OF GENERIC CHANGES TO NUREG-1430, REVISION 3.1 The following Nuclear Regulatory Commission (NRC)-approved (as of June 30, 2007) Technical Specification Task Force (TSTF) changes are adopted in whole or in part in the Davis-Besse Nuclear Power Station (DBNPS) Improved Technical Specifications (ITS) submittal:
TSTF 412, Rev. 3 448, Rev. 3 471, Rev. 1 491, Rev. 2 497, Rev. 0 Affected ITS 3.7.5 3.7.10, 5.5 1.1, 3.8.2, 3.8.5, 3.8.8, 3.8.10, 3.9.1, 3.9.2, 3.9.3 3.7.2, 3.7.3 5.5 The following NRC-approved (as of June 30, 2007) TSTF changes have not been included in the DBNPS ITS submittal:
TSTF 427, Rev. 2 Description of TSTF and Reason for Not Adopting TSTF The TSTF added a new LCO Applicability requirement, LCO 3.0.9, to address barriers that cannot perform their related support function for Technical Specification Systems.
DBNPS does not desire to include this technical, less restrictive LCO allowance at this time.
The TSTF deletes the current limits on primary coolant gross specific activity (E-bar) and replaces these limits with primary coolant noble gas activity limits based on DOSE EQUIVALENT XE-135.
DBNPS does not desire to pursue this technical, less restrictive change at this time.
Affected ITS 3.0 490, Rev. 0 1.1, 3.4.16
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 2 of 2 DISPOSITION OF GENERIC CHANGES TO NUREG-1430, REVISION 3.1 The following TSTF "T" traveler changes are adopted in whole or in part in the DBNPS ITS submittal:
TSTF Affected ITS 402T, Rev. 1 3.8.1 45 IT, Rev. 0 3.8.4, 5.5 467T, Rev. 0 3.1.9 494T, Rev. 0 3.0
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 1 of I DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS Affected ITS Submittal Affected CTS Date Description of Change Sections/Specifications Pages Disposition 2/12/07 Davis-Besse Nuclear Power ITS: 3.9.3 3/4 9-4 Proposed changes are already Station, Docket Number 50-346, reflected in this ITS submittal.
Administrative Control of Changes are annotated with an "A" Penetrations During Refueling DOC referencing the previously (LAR No. 06-0002) (TAC No.
submitted LAR. See ITS 3.9.3 MD4421)
DOC A02.
4/12/07 Davis-Besse Nuclear Power ITS: 1.0, 3.3.1, 3.7.6, and 1-I, 2-5, 2-6, Proposed changes are already Station License Amendment 5.6 3/4 3-7, 3/4 7-6, reflected in this ITS submittal.
Application for Measurement and 6-14 Changes are annotated with an "A" Uncertainty Recapture Power DOC referencing the previously Upratc (LAR No. 05-0007) submitted LAR. See ITS Chapter (TAC No. MD4452) 1.0 DOC A18, ITS 3.3.1 DOC A13, ITS 3.7.6 DOC A04, and ITS 5.6 DOC A08.
Docket Number 50-346 License Number NPF-3 Serial Number 3351 Page 1 of I COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please contact Mr. Thomas A. Lentz, Manager - FENOC Fleet Licensing, at (330) 761-6071 of any questions regarding this document or any associated regulatory commitments.
COMMITMENT DUE DATE
- 1. Following implementation actions are completed.
of the approved license amendment.
- 2. The following guidelines will be included in the
- 2. Upon implementation of assessment of systems removed from service during the approved license movement of irradiated fuel:
amendment.
During fuel handling/core alterations, ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel.
Following shutdown, radioactivity in the fuel decays away fairly rapidly. The basis of the Technical Specification operability amendment is the reduction in doses due to such decay. The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay.
A single normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure.
The purpose of the "prompt methods" mentioned above are to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.
[Reference NUREG-1430 Bases 3.9.3 Reviewer's Note regarding the term "recently" associated with handling irradiated fuel, consistent with NUMARC 93-01, Revision 4, Section 11.3.6.5.1