Text

Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 1 of 8
	ML15176A664
Person / Time
Site:	Sequoyah
Issue date:	06/19/2015
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML15176A678	List: CNL-15-128, Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; ML15176A664; ML15176A679; ML15176A681; ML15176A682; ML15176A718; ML15176A740; ML15176A748; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 1 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 2 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 3 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 4 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 7 of 8;
References
	SQN-TS-11-10, CNL-15-128
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ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 SQN ITS Conversion RAI Database ITS NRC Questions Id 188NRC Question Number CET001 Category Technical ITS Section 3.6 ITS Number 3.6.10DOC Number JFD Number JFD Bases Number Page Number(s) 441NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Ahsan Sallman Conf Call Requested NNRC Question The proposed ITS SR 3.6.10.4 in page 441 states: "Verify ea ch EGTS filter cooling bypass valve can be operated."

This statement differs from NUREG 1431 Volume 1 SR 3.6.13.4 by changing the term "opened"to "operated.""Operated"could be interpreted as simply verifying the "open"and "closed"position of the valve by inje cting a fictitious signal to the operator, i.e. wi thout actually opening of the valve.Please ensure consistency with STS by retaining the word "opened"in order to make sure both oper ator and valve are tested.

If you choose to reta in the word "operated,"please provide an explanation of "operated"in the ITS SR to provide clear expectation that the intent of the surveillance requirement is to test the operator and the valve for opening.Attach File 1 Attach File 2 Issue Date 9/4/2014Added By Caroline TiltonDate Modified Modified By Date Added 9/4/2014 8:49 AMNotification Scott BowmanPage 1of 2 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=188 Michelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottCaroline TiltonPage 2of 2 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=188 Licensee Response/NRC Response/NRC Question Closure Id 348NRC Question Number CET001Select Application Licensee ResponseAttachment 1 Attachment 2 Response Statement In response to CET001, the following information is provided to justify that ITS SR 3.6.10.4, "Verify each EGTS filter train cooling bypass valve can be operated,"is equivalent to the STS language that requires verifying the EGTS cooling bypass valves can be opened.The SQN Surveillance Instructions used to demonstrate the operability of each EGTS filter cooling bypass valve require each valve go to the open position when the associated handswitch is placed in P-AUTO and return to the closed position when the handswitch is placed in the CLOSE position.The acceptance criteria requires verification that each valve opens and closes.Therefore, ITS SR 3.6.10.4, as proposed, will require verification that the valves can open when operated from the associated handswitch.Response Date/Time 9/25/2014 11:15 AM Closure Statement Question Closure Date Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonRay SchieleCaroline TiltonAdded By Scott BowmanDate Added 9/25/2014 10:10 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=348 Licensee Response/NRC Response/NRC Question Closure Id360NRC Question Number CET001Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 9/26/2014Notification Scott Bowman Michelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Caroline Tilton Date Added 9/26/2014 10:26 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=360 ITS NRC Questions Id189NRC Question Number CET002 Category TechnicalITS Section 3.6ITS Number 3.6.13DOC Number JFD Number JFD Bases Number Page Number(s) 564NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Ahsan SallmanConf Call Requested NNRC Question On page 564, the proposed Note 2 under ACTION S in ITS 3.6.13 states:"When an ice condenser intermediate deck or top deck door is inoperable for a short duration solely due to personnel standing on or opening the door to perform required Surveillances, minor preventative maintenance, or system walkdowns, entry into associated Conditions and Required Actions is not required."Please define "short duration"and provide the bases for that definition.

Include in the discussion any impact these allowed activities would have on the operability of th e isolation condenser a nd how ice sublimation would be prevented.

Attach File 1 Attach File 2 Issue Date 9/8/2014Added By Caroline TiltonDate Modified Modified By Date Added 9/8/2014 1:20 PMNotification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottCaroline TiltonPage 1of 1 Sequoyah ITS Conversion Databas e 9/25/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id336NRC Question Number CET002Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question has been withdrawn. No further information is required at this time to draft the Safety Evaluation.Question Closure Date 9/17/2014Notification Scott Bowman Michelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Caroline Tilton Date Added 9/17/2014 12:51 PMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 9/25/201 4htt p s://members.excelservices.com/rai/index.

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ITS NRC Questions Id 204NRC Question Number CET003 Category Technical ITS Section 3.6 ITS Number 3.6.7 DOC Number JFD Number JFD Bases Number Page Number(s) NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Mark Blumberg Conf Call Requested NNRC Question Enclosure 2, Volume 11, Rev. 0, Page 344 of 724, contains Sequoyah's proposed ITS LCO 3.6.7, "Shield Building."In converting to NUREG-1431, "Standard Technical Specifications (STS) for Westinghouse Plants,"the licensee documented L01, the less restrictive change, but did not fully address the design differences.Sequoyah's shield building design is unique and differs from the design in the STS 3.6.8.STS 3.6.8 Condition A's completion time is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .Sequoyah must establish a proper technical basis to adopt STS 3.6.8.

L01 did not provide a technical basis to support incorporation of the 24 completion time. Please respond with one of the following options:Please provide analyses that show that with the proposed change that the applicable regulatory limits (Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC) 19, 41, 60, 61, 64, 10 CFR, Part 100, "Reactor Site Criteria,"and 10 CFR, Section 50.67, "Accident source term"(10 CFR 50.67)) continue to be met for all accidents and anticipated operational occurrences in the design bases.Provide the methods, acceptance criterion, inputs and assumptions used to make this determination and a justification for each change from the current licensing basis.If the boundary restoration is credited using human actions, please justify how these actions can be assured to be completed with the potential for harsh environments (radiation, temperature, pressure, humidity, or failure of high energy pipes) which could impede or prevent human actions.Please specify and justify the methods used to make these determinations (e.g. RGs, Standard Review Plan Section 18.0, "Human Factors Engineering"(Adams Accession No. ML070670253 etc.)).Consistent with the requirements of NUREG-0737, "Clarification of TMI Action Plan Requirements,"Task Action II.B.2, justify how these actions can be completed without exceeding the acceptance criteria (typically contained in GDC 19) for mission doses.In addition, describe the actions taken to compensate for the inability of closing the boundary using Page 1of 2 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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engineered controls and justify the reliability of these methods (e.g. during maintenance on a boundary door).Alternatively, restore to the current licensing basis for the Shield Building and the Emergency Gas Treatment System.

Attach File 1 Attach File 2 Issue Date 12/8/2014Added By Khadijah HemphillDate Modified Modified By Date Added 12/8/2014 2:43 PMNotification Mark BlumbergScott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn Mynatt Ray SchieleRoger ScottCaroline TiltonPage 2of 2 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id415 NRC Question Number CET003 Select Application Licensee Response Attachment 1 CET003 Attachment 1 -Pages from SQN UFSAR.pdf (325KB)Attachment 2 CET003 Attachment 2 -Restore CLB to ITS 3.6.7 and 3.6.10 12-23-14.pdf (5MB)Response Statement In response to request for additional information (RAI) CET-003, the Tennessee Valley Authority (TVA) has elected to restore the Sequoyah Nuclear Plant (SQN), Units 1 and 2, current licensing basis for the shield building and the Emergency Gas Treatment System (EGTS) except for the relocation of the technical details of the current Technical Specification (CTS) definition of SHIELD BUILDING INTEGRITY and the change to the frequency of CTS 4.6.1.8.d.4.

As described in the SQN Updated Final Safety Analysis Report (UFSAR), the containment for each of the reactors consists of a freestanding steel vessel with an ice condenser and separate reinforced concrete shield building.The Shield Building annulus serves as a redundant second containment barrier for control of radioactivity leakage.As described in UFSAR Subsection 3.8.4.1.1, "Auxiliary Control Building,"and shown on UFSAR Figure 1.2.3-5, access to the annulus is via the reactor building access room door and a water tight annulus access door at plant elevation 690.0 ft.During normal operation, these doors provide personnel and equipment access to the shield building annulus area and are equipped with electrical interlocks to ensure that one door is always closed (UFSAR pg. 3.8

-77).Attachment 1 to this RAI provides UFSAR Figure 1.2.3-5 that shows the shield building annulus area personnel access location for SQN, Units 1 and 2 and UFSAR pages 3.8-76 and 3.8

-77 that provide the description of the access doors to the annulus area; Doors A64 and A65; and Doors A77 and A78.Attachment 2 to this RAI provides markup pages of Enclosure 2, Volumes 3 and 11 of the Improved Technical Specifications (ITS) license amendment request (LAR) dated November 11, 2013 (ADAMS Accession Nos. ML13329A790 and ML13330A931) and restores the SQN, Units 1 and 2 current licensing basis for the shield building and EGTS except for the following:Relocate technical details of the CTS definition of SHIELD BUILDING INTEGRITY to the Bases of ITS 3.6.7, "Shield Building"(ITS 3.6.7 Discussion of Changes (DOC) LA04) that results in the deletion of this definition (ITS 1.0 DOC A06) from the CTS.Change in frequency of CTS 4.6.1.8.d.4 from "at least once per 18 months" to "18 months on a STAGGERED TEST BASIS (ITS 3.6.7 DOC L02 moved to ITS 3.6.10 DOC L05).Moving the specified frequency of CTS 4.6.1.8.d.4 to the Surveillance Frequency Control Program (ITS 3.6.7 DOC LA03 deleted and details

incorporated into ITS 3.6.10 DOC LA02)Page 1of 4 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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As a result of the relocation of the technical details and deletion of the CTS definition of SHIELD BUILDING INTEGRITY, the following changes are being made to ITS 1.0, Use and Application, of Enclosure 2 of the ITS LAR:CTS 1.0 markups are revised to delete the SHIELD BUILDING INTEGRITY and DOC A06 indicator is added (Enclosure 2, Volume 3, Rev. 0, Pages 14 and 32 of 117).SHIELD BUILDING INTEGRITY is added to the list of deleted definitions in ITS 1.0 DOC A06 (Enclosure 2, Volume 3, Rev. 0, Page 45 of 117).The following changes are being made to ITS 3.6.7, Shield Building of Enclosure 2 of the ITS LAR:CTS 3.6.1.7 and 4.6.1.7 markups are revised to delete DOC L01, delete proposed SR 3.6.7.1 and SR 3.6.7.2. These revisions include changes to applicable DOC and ITS indicators (Enclosure 2, Volume 11, Rev. 0, Pages 330 and 334 of 724).CTS markups are revised to move CTS 4.6.1.8.d.4 to ITS 3.6.10 and delete Insert 1.This revision includes changes to applicable DOC and ITS indicators (Enclosure 2, Volume 11, Rev. 0, Pages 331, 332, 335, and 336 of 724).CTS markups are revised to delete CTS 1.30.a. Applicable DOC and ITS indicators are revised to reflect the relocation of this information to the Bases of ITS 3.6.7 (Enclosure 2, Volume 11, Rev. 0, Pages 333 and 337 of 724).ITS 3.6.7 DOCs A02, LA02, and LA04 are revised; ITS 3.6.7 DOCs M01, LA03, L01, and L02 are deleted (Enclosure 2, Volume 11, Rev. 0, Pages 338 through 342 of 724).Improved Standard Technical Specifications (ISTS) 3.6.8 (ITS 3.6.7) markups are revised to delete Insert 1 and revise the Completion Time of Required Action A.1 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In addition, ISTS SRs 3.6.8.1, 3.6.8.2, and 3.6.8.4 are deleted and ISTS SR 3.6.8.3 is re-numbered.These revisions include changes to applicable Justification for Deviations (JFD) and CTS indicators (Enclosure 2, Volume 11, Rev. 0, Pages 344 through 349 of 724).ITS 3.6.7 JFDs 3, 5, 6, and 7 are deleted and replaced with the justification for changing the Completion Time of Required Action A.1 from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (JFD 3), justification for deleting ISTS SRs 3.6.8.1 and 3.6.8.2 (JFD 5), and justification for moving ISTS SR 3.6.8.4 to ITS 3.6.10 (ISTS 3.6.13) (JFD 6) (Enclosure 2, Volume 11, Rev. 0, Page 350 of 724).The ISTS 3.6.8 (ITS 3.6.7) Bases markups are revised to align with changes made to the Specification and includes the relocation of technical details of the SHIELD BUILDING INTEGRITY definition stated in CTS 1.30.a.These revisions include changes to applicable Bases JFDs (Enclosure 2, Volume 11, Rev. 0, Pages 352 through 361 of 724).ITS 3.6.7 Bases JFDs are revised to delete JFDs 5 and 7 because they are no longer applicable and Bases JFD 8 is renumbered (Enclosure 2, Volume 11, Rev. 0, Page 362 of 724).The following changes are being made to ITS 3.6.10, Emergency Gas Treatment System (EGTS) of Enclosure 2 of the ITS LAR:Attachment 10 is retitled, "ITS 3.6.10, Emergency Gas Treatment System (EGTS) Air Cleanup Subsystem,"consistent with the TVA response to RAI CSS-041 (Enclosure 2, Volume 11, Rev. 0, Page 424 of 724).Page 2of 4 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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CTS markups are revised to incorporate CTS 4.6.1.8.d.4 into ITS 3.6.10 as SR 3.6.10.6 and add Insert 1 (Insert Page 3/4 6-14).This revision includes changes to applicable DOC and ITS indicators (Enclosure 2, Volume 11, Rev. 0, Pages 427 and 431 of 724).Unit 2 CTS page 1-6 markup is revised to indicate that CTS 1.30.a is addressed in ITS 3.6.7 (Enclosure 2, Volume 11, Rev. 0, Page 433 of 724).The Unit 1 CTS page was correctly marked in Revision 0 of the ITS LAR.ITS 3.6.10 DOC LA02 is revised to include Insert 2 (Insert Page 2 of 5); and ITS 3.6.10 DOC L05 is added as Insert 3 (Insert Page 5 of 5) (Enclosure 2, Volume 11, Rev. 0, Pages 435 and 438 of 724).ISTS 3.6.13 (ITS 3.6.10) markups are revised to include SR 3.6.10.6 as Insert 1 (Insert Page 3.6.10-2).These revisions include changes to applicable JFD and CTS indicators.Additionally, "Air Cleanup Subsystem,"is added to EGTS consistent with TVA response to RAI CSS-041 (Enclosure 2, Volume 11, Rev. 0, Pages 441 and 443 of 724).ITS 3.6.10 JFD 5 is added with the justification for the addition of ITS SR 3.6.10.6 to ITS 3.6.10 (ISTS 3.6.13) (Enclosure 2, Volume 11, Rev. 0, Page 444 of 724).The ISTS 3.6.13 (ITS 3.6.10) Bases markups are revised to align with changes made to the Specification and include, "Air Cleanup Subsystem,"to EGTS consistent with TVA response to RAI CSS-041.These revisions include a Bases discussion regarding SR 3.6.10.6 (Insert 4 -Insert B 3.6.10.6) and the applicable Bases JFD (Enclosure 2, Volume 11, Rev. 0, Pages 446, 447, 454, 455, 456, and 463 of 724).The NRC provided two RAIs, TVA responded, and the NRC staff subsequently closed:RAI CSS-021 addressed the change to the Frequency of CTS 4.6.1.8.d.4 (RAI CSS-021).TVA responded to RAI CSS-021 on August 4, 2014 and the NRC staff closed the RAI on September 4, 2014, stating that no further information is required.RAI CSS-041 addressed the EGTS design consisting of two subsystems; the annulus vacuum control subsystem and the air cleanup subsystem.Per TVA response to RAI CSS-041, ITS 3.6.10 is being revised to rename the Emergency Gas Treatment System as the Emergency Gas Treatment System (EGTS) Air Cleanup Subsystem.All references to the Emergency Gas Treatment System and EGTS are being revised to reflect this nomenclature.This change affects ITS 3.6.7 and ITS 3.6.10 and is reflected in the attachments to TVA response to RAI CSS-041, dated August 20, 2014.The NRC staff closed the RAI on August 26, 2014, stating that no further information is required.Response Date/Time 1/2/2015 11:55 PMClosure Statement Question Closure Date Notification Mark BlumbergScott BowmanKristy BucholtzMargaret ChernoffPage 3of 4 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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Michelle ConnerRobert ElliottRavinder GroverMatthew Hardgrove Khadijah HemphillAndrew HonLynn MynattAmrit PatelRay SchieleCaroline Tilton Added By Michelle Conner Date Added 1/2/2015 10:57 PMDate Modified Modified By Page 4of 4 Sequoyah ITS Conversion Databas e 3/17/201 5htt p s://members.excelservices.com/rai/index.

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S3-08.doc 3.8-76 SQN The door and door track are constructed of welded steel. The door, rectangular in cross section, is constructed of horizontal and vertical members with diagonal bracing as required for strength and rigidity. The exterior side of the door is covered with a steel skin plate. The embedded frame for the door is constructed of welded steel and is anchored to the concrete.

The door seals in the closed position with the side and top seals compressed against sealing surfaces on the embedded frame and the bottom seal compressed against an embedded sill plate. A sloped track guides the door rollers and positions the door so that the top and side seals contact the sealing surfaces only when the door is in or near the closed position.

An electric hoist unit opens and closes the door by lifting and lowering it vertically through a slot in the Elevation 734.0 floor. The hoist unit is mounted on the inside wall above the door slot. The door passes through this slot, and extensions of the frame act as guides for the door in the raised position.

The area above the floor at Elevation 734.0, occupied by the hoist and the door in its raised position, is enclosed with an airtight structural steel enclosure with gaskets provided on the access covers necessary for servicing the hoist unit and door.

Pressure Confining Personnel Doors

This section covers the following pressure confining personnel access control doors located in the Auxiliary Control Building. Door numbers listed for the doors are the designations used in in the plant.

1. The doors for stairs 7 and 8 penthouses at Elevation 749.0, doors A184 and A191.

2. The double doors to the personnel and equipment access rooms, elevation 734.0 (one for each unit), doors A152 and A159.

3. The double doors at the Ice Condenser Equipment Room, Elevation 734.0, door A155.

4. The double doors to the Emergency Gas Treatment Filter Room, Elevation 734.0, door A158.

5. The doors to the Reactor Building Access Room at Elevation 734.0 (one for each unit), doors A156 and A157.

6. The doors for stairs 3 and 4 penthouses at Elevation 734.0, doors A154 and A173.

7. The double doors to the elevator shaft at Elevation 734.0, door A153.

8. The N-line control bay doors at Elevation 732.0 (two double doors with bidirectional pressure requirements, doors C36 and C54) and elevation 706.0 (two double doors with bidirectional pressure requirements, doors C29 and C34).

S3-08.doc 3.8-77 SQN-23 9. The double doors to the heating and ventilating spaces at Elevation 714.0 (one for each unit), doors A123 and A132.

10. The door separating the Additional Equipment Building and the airlock at Elevation 714.0 (one for each unit, bidirectional pressure requirements), doors A214 and A215.

11. The door to the Cask Decontamination Room, Elevation 705.0, door A115.

12. The doors in the X-line wall of the cask loading area at Elevation 706.0 (one single door A113 and one double door A114).

13. The water tight doors leading to the instrument room at Elevation 685.0; one in N-line wall, C27, and one in C3-line wall, C14.

14. The doors to the Main Steam and Feedwater Valve Rooms at Elevation 706.0 (one for each unit), doors A101 and A105.

15. The water tight double doors at the main entrance from the Service Building, Elevation 690.0, door A57.

16. The water tight annulus access doors (one per unit, doors A65 and A78) and doors to the Reactor Building Access Rooms (one per unit, doors A64 and A77) at Elevation 690.0.

17. The water tight airlock door to the Radiochemical Laboratory at Elevation 690.0, door A55.

The doors are hinged, manually operated type metal doors, complete with frames and closers. The frames are either welded to plates, bolted to the concrete walls, embedded in concrete walls, or welded to embedded plates. Both single and double doors are involved. Double doors consist of an active and inactive leaf, with the active leaf being used for normal traffic. Doors C27, A55, A57, A65 and A78 have a single skin plate with horizontal stiffeners. All other doors are the flush type. Securing for tornado, annulus pressure drop, or flood is done by a normal latching mechanism except for doors C27, A55, A57, A65 and A78 which are secured by the use of hand-operated dogs. All doors affected by tornadoes are secured during tornado warning and doors A65 and A78 are secured during external flood warnings. Doors A55, A57, C27, and C14 will protect essential safety equipment in the auxiliary and control buildings to elevation 706.0 from internal floodwaters in the turbine building caused by a rupture in the Condenser Circulating Water system (CCWS).

During normal operation the doors provide personnel and equipment access. Doors A55, A57, A64, A65, A77, A78, A101, A105, A 113, A114, A123, A132, A214, and 215 are also components of the building airlocks which serve to maintain a slight negative pressure in the Auxiliary and Reactor Buildings. These doors are equipped with electrical interlocks to assure that one of each pair of interlocked doors is always closed.

Spent Fuel Pool Gates The fuel transfer canal gate as shown in Figure 3.8.4-11, when in the installed position, forms the boundary between the fuel transfer canal and the spent fuel pool. This gate is used for ATTACHMENT 1 ITS 1.0, USE AND APPLICATION

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS Chapter 1.0 SHIELD BUILDING INTEGRITY 1.30 SHIELD BUILDING INTEGRITY shall exist when:

a. The door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

b. The emergency gas treatment system is OPERABLE.

c. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.

SHUTDOWN MARGIN 1.31 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY

1.32 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

SOLIDIFICATION 1.33 Deleted SOURCE CHECK

1.34 Deleted STAGGERED TEST BASIS 1.35 A STAGGERED TEST BASIS shall consist of

a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals,

b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

THERMAL POWER

1.36 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

August 2, 2006 SEQUOYAH - UNIT 1 1-6 Amendment No. 12, 71, 48, 155, 294, 297, 309 (SDM) SDM: a. RCCARCCAs INSERT 7 A01 A12 A06 A07 A07INSERT 9 A13 A02 A01 , SHUTDOWN MARGIN (SDM) STAGGERED TEST BASIS THERMAL POWER Page 10 of 37 See ITS 3.6.3 See ITS 3.6.13 See ITS 3.6.1 controlINSERT 8 See ITS 3.6.3 3.6.13 3.6.1 Chapter 1.0 ITS DEFINITIONS RATED THERMAL POWER (RTP) 1.27 RATED THERMAL POWER (RTP) shall be a total reactor core heat transfer rate to the reactor coolant of 3455 MWt.

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME 1.28 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its (RTS) trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by NRC.

REPORTABLE EVENT

1.29 DELETED SHIELD BUILDING INTEGRITY 1.30 SHIELD BUILDING INTEGRITY shall exist when:

a. The door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

b. The emergency gas treatment system is OPERABLE.

c. The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.

SHUTDOWN MARGIN

1.31 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY 1.32 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

August 2, 2006 SEQUOYAH - UNIT 2 1-6 Amendment No. 63, 132, 146, 242, 264, 267, 284, 298 RATED THERMAL POWER (RTP)

A01 RTS that the REACTOR TRIP SYSTEM (RTS) RESPONSE TIME A01 A07Page 28 of 37 See ITS 3.6.3 See ITS 3.6.13 See ITS 3.6.1 See ITS 3.6.3 3.6.13 3.6.1 SHUTDOWN MARGIN (SDM) (SDM) SDM : a. RCCA INSERT 7 RCCAs , A01 A12 A06control DISCUSSION OF CHANGES ITS 1.0, USE AND APPLICATIONS Sequoyah Unit 1 and 2 Page 4 of 11 to the CHANNEL FUNCTIONAL TEST for digital channels was consistent with the existing channel functional test definition and therefore acceptable.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A05 CTS Section 1.0 includes a CHANNEL FUNCTIONAL TEST definition for bistable channels. The definition of CHANNEL FUNCTIONAL TEST for bistable channels requires "the injection of a simulated signal into the channel sensor to verify OPERABILITY including alarm and/or trip functions." However, this CTS definition is essentially duplicative of the TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) definition. ITS Section 1.1 does not include this definition, since the requirements for bistable channels are covered by the TADOT definition.

This change is acceptable because the TADOT definition adequately covers bistable channels, and does not impose any new requirements or alter any existing requirements. This change is categorized as administrative because the bistable portion of the definition is duplicative of the TADOT definition.

A06 CTS Section 1.0 includes the following definitions:

CONTAINMENT INTEGRITY GASEOUS RADWASTE TREATMENT SYSTEM PURGE - PURGING SITE BOUNDARY UNRESTRICTED AREA VENTILATION EXHAUST TREATMENT SYSTEM VENTING E - AVERAGE DISINTEGRATION ENERGY CORE ALTERATION

The ITS does not use this terminology and ITS Section 1.1 does not contain these definitions.

These changes are acceptable because the terms are not used as defined terms in the ITS. Discussions of any technical changes related to the deletion of these terms are included in the DOCs for the CTS sections in which the terms are used. These changes are designated as administrative because they eliminate defined terms that are no longer used.

A07 CTS Section 1.0 shows the following definitions as being deleted:

CONTROLLED LEAKAGE MEMBER(S) OF THE PUBLIC PROCESS CONTROL PROGRAM (PCP) REPORTABLE EVENT SOLIDIFICATION SOURCE CHECK

ATTACHMENT 7 ITS 3.6.7, SHIELD BUILDING

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

CONTAINMENT SYSTEMS SHIELD BUILDING STRUCTURAL INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.7 The structural integrity of the shield building shall be maintained at a level consistent with the acceptance criteria in Specification 4.6.1.7.

APPLICABILITY

MODES 1, 2, 3 and 4.

ACTION: With the structural integrity of the shield building not conforming to the above requirements, restore the structural integrity to within the limits prior to increasing the Reactor Coolant System temperature above 200°F.

SURVEILLANCE REQUIREMENTS

4.6.1.7 The structural integrity of the shield building shall be determined during the shutdown for each Type A containment leakage rate test (Specification 4.6.1.1.c) by a visual inspection of the exposed accessible interior and exterior surfaces of the shield building and verifying no apparent changes in appearance of the concrete surfaces or other abnormal degradation.

May 24, 2002 SEQUOYAH - UNIT 1 3/4 6-12 Amendment No. 36, 176, 276 ITS LCO 3.6.7 A pplicability A CTION A A01 3.6.7 Page 1 of 8OPERABLE LA01Add proposed ACTION A A CTION B Add proposed ACTION B A02 L01 SR 3.6.7.3 LA02Add proposed SR 3.6.7.1 at a Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months M01SR 3.6.1.1 Add proposed SR 3.6.7.2 at a Frequency of 31 days In accordance with the Surveillance Frequency Control Program LA03 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30

°C (86°F) and a relative humidity of 70%.

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined H EPA filters and charcoal adsorber banks is less than 5 inches Water Gauge while operating the filter train at a flow rate of 4000 cfm

+/- 10%. 2. Verifying that the filter train starts on a Phase A containment isolation Test Signal.

3. Verify the operation of the filter cooling bypass valves.

4. Verifying that each system produces a negative pressure of greater than or equal to 0.5 inches W. G. in the annulus within 1 minute after a start signal.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm +/- 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm

+/- 10%.

November 2, 2000 SEQUOYAH - UNIT 1 3/4 6-14 Amendment No. 21, 88, 103, 263 See ITS 5.5.9 See ITS 3.6.10 See ITS 5.5.9 ITS A01 3.6.7 Page 2 of 8 SR 3.6.7.4 INSERT 1 L02 SR 3.6.7.4

3.6.7 Insert Page 3/4 6-14 INSERT 1 on a STAGGERED TEST BASIS for each Emergency Gas Treatment System train

M02 L02In accordance with the Surveillance Frequency Control Program LA03 Page 3 of 8 SHIELD BUILDING INTEGRITY 1.30 SHIELD BUILDING INTEGRITY shall exist when:

a. The door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

b. The emergency gas treatment system is OPERABLE.

c. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0

-rings) is OPERABLE.

SHUTDOWN MARGIN 1.31 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY

1.32 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

SOLIDIFICATION 1.33 Deleted

SOURCE CHECK

1.34 Deleted

STAGGERED TEST BASIS 1.35 A STAGGERED TEST BASIS shall consist of:

a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals,

b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

THERMAL POWER

1.36 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

August 2, 2006 SEQUOYAH - UNIT 1 1-6 Amendment No. 12, 71, 48, 155, 294, 297, 309 ITS A01 3.6.7 Page 4 of 8 See ITS Chapter 1.0LCO 3.6.7 Note See ITS 3.6.10 NA See ITS Chapter 1.0 LA04 CONTAINMENT SYSTEMS SHIELD BUILDING STRUCTURAL INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.7 The structural integrity of the shield building shall be maintained at a level consistent with the acceptance criteria in Specification 4.6.1.7.

APPLICABILITY

MODES 1, 2, 3 and 4.

ACTION.

With the structural integrity of the shield building not conforming to the above requirements, restore the structural integrity to within the limits prior to increasing the Reactor Coolant System temperature above 200°F.

SURVEILLANCE REQUIREMENTS 4.6.1.7 The structural integrity of the shield building shall be determined during the shutdown for each Type A containment leakage rate test (Specification 4.6.1.1.c) by a visual inspection of the exposed accessible interior and exterior surfaces of the shield building and verifying no apparent changes in appearance of the concrete surfaces or other abnormal degradation.

May 24, 2002 SEQUOYAH - UNIT 2 3/4 6-12 Amendment No. 28, 167, 267 ITS LCO 3.6.7 A pplicability A CTION A A01 3.6.7 Page 5 of 8OPERABLE LA01Add proposed ACTION A A CTION B Add proposed ACTION B A02 L01 SR 3.6.7.3 LA02 M01SR 3.6.1.1 Add proposed SR 3.6.7.1 at a Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Add proposed SR 3.6.7.2 at a Frequency of 31 days In accordance with the Surveillance Frequency Control Program LA03 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30

°C (86° F) and a relative humidity of 70%. d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5 inches Water Gauge while operating the filter train at a flow rate of 4000 cfm + 10%. 2. Verifying that the filter train starts on a Phase A containment isolation Test Signal.

3. Verify the operation of the filter cooling bypass valves.

4. Verifying that each system produces a negative pressure of greater than or equal to 0.5 inches W.G. in the annulus within 1 minute after a start signal.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm + 10%. f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm + 10%.

November 2, 2000 SEQUOYAH - UNIT 2 3/4 6-14 Amendment No. 11, 77, 92, 254 See ITS 5.5.9 See ITS 3.6.10 See ITS 5.5.9 ITS A01 3.6.7 Page 6 of 8 SR 3.6.7.4 SR 3.6.7.4 INSERT 1 L02 LA03 3.6.7 Insert Page 3/4 6-14 INSERT 1 on a STAGGERED TEST BASIS for each Emergency Gas Treatment System train

M02 L02In accordance with the Surveillance Frequency Control Program LA03 Page 7 of 8 DEFINITIONS RATED THERMAL POWER (RTP) 1.27 RATED THERMAL POWER (RTP) shall be a total reactor core heat transfer rate to the reactor coolant of 3455 MWt.

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME 1.28 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its (RTS) trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by NRC.

REPORTABLE EVENT

1.29 DELETED

SHIELD BUILDING INTEGRITY 1.30 SHIELD BUILDING INTEGRITY shall exist when:

a. The door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

b. The emergency gas treatment system is OPERABLE.

c. The sealing mechanism associated with each penetration (e.g., welds, bellows or O-rings) is OPERABLE.

SHUTDOWN MARGIN

1.31 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY 1.32 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

August 2, 2006 SEQUOYAH - UNIT 2 1-6 Amendment No. 63, 132, 146, 242, 264, 267, 284, 298 ITS A01 3.6.7 Page 8 of 8 See ITS Chapter 1.0LCO 3.6.7 Note See ITS 3.6.10 See ITS Chapter 1.0 See ITS Chapter 1.0 LA04 NA DISCUSSION OF CHANGES ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 1 of 5 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 4.0, "Standard Technical Specifications- Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this

submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.6.1.7 does not provide an ACTION to take if the shield building is inoperable while in MODE 1, 2, 3, or 4; it only includes a requirement that the shield building be restored to OPERABLE status prior to increasing Reactor Coolant System temperature above 200°F (i.e., MODE 4). Therefore, entry into CTS 3.0.3 is required if CTS 3.6.1.7 is not met while in MODE 1, 2, 3, or 4. CTS 3.0.3 requires action to be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to prepare for a shutdown and requires the unit to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . When the shield building is inoperable and not restored to an OPERABLE status within the specified Completion Time (see DOC L01), ITS 3.6.7 ACTION B requires the unit be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by stating the ACTIONS within the Specification rather than deferring to CTS 3.0.3. In addition, it deletes the Action to restore the LCO prior to entering MODE 4.

The purpose of CTS 3.0.3 is to place the unit outside the MODE of Applicability within a reasonable amount of time in a controlled manner. CTS 3.6.1.7 is silent on these actions, deferring to CTS 3.0.3 for the actions. This change is acceptable because the ACTIONS specified in ITS 3.6.7 adopt ISTS structure for placing the unit outside the MODE of Applicability without changing the time specified to enter MODE 3 and MODE 5. In addition, deletion of the current Action of CTS 3.6.1.7 is acceptable because CTS 3.0.4 (ITS LCO 3.0.4) already precludes entering the MODE of Applicability when the LCO is not met.

Therefore, it is not necessary to include these requirements as specific actions in ITS 3.6.7. This change is designated as administrative, because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES

M01 ITS SR 3.6.7.1 requires verification that annulus negative pressure is greater than 5 inches water gauge every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.6.7.2 requires verification that the shield building access door in each access opening is closed every 31 days. CTS 3.6.1.7 does not contain these Surveillance Requirements. This changes the CTS by adding new Surveillance Requirements to verify annulus negative pressure is within limits and to verify the shield building access door in each access opening is closed. (See DOC LA03 for moving the "12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " and "31 day" Frequencies for these Surveillance Requirements to the Surveillance Frequency Control Program.)

DISCUSSION OF CHANGES ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 2 of 5 The shield building surrounds the containment vessel and forms an annulus between the containment vessel and the inner wall of the shield building. This annular space collects containment leakage that may occur following a loss of coolant accident. A negative pressure is maintained in the annulus between the shield building and the steel containment vessel by the Emergency Gas Treatment System (EGTS). The release of radioactive contaminants to the environment is controlled via filters in the EGTS trains. The purpose of CTS 3.6.1.7 is to ensure the shield building is OPERABLE in MODES 1, 2, 3, and 4 to ensure the release of radioactive material from the containment atmosphere is restricted to the leakage paths assumed in the accident analysis.

Since shield building access door position and annulus pressure are integral to shield building OPERABILITY, ITS 3.6.7 adds a specific Surveillance Requirement (ITS SR 3.6.7.1) to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that annulus negative pressure is within the limit assumed in the containment analysis. Additionally, a specific Surveillance Requirement (ITS SR 3.6.7.2) is added to verify every 31 days that the door in each access opening is closed, so that the shield building boundary is not breached at any time when the shield building boundary is required. This change is designated as more restrictive because new Surveillance Requirements have been added to ensure the shield building OPERABILITY is maintained.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES LA01 CTS 3.6.1.7 requires that the structural integrity of the shield building be maintained at a level consistent with the acceptance criteria in CTS 4.6.1.7. CTS 4.6.1.7 requires the structural integrity of the shield building to be determined by a visual inspection of the exposed shield building interior and exterior surfaces and verifying no apparent changes in concrete surface appearance or other abnormal degradation. ITS LCO 3.6.7 requires the shield building to be OPERABLE. This changes the CTS by moving the detail of what constitutes shield building OPERABILITY to the Bases.

The removal of these details, related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirements that the shield building be OPERABLE. Also, this changes is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

DISCUSSION OF CHANGES ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 3 of 5 LA02 CTS 4.6.1.7 requires the structural integrity of the shield building to be determined by a visual inspection of the exposed shield building interior and exterior surfaces and verifying no apparent changes in concrete surface appearance or other abnormal degradation. ITS SR 3.6.7.3 includes the shield building structural integrity visual inspection verification of exposed interior and exterior surfaces, but does not include the details of what the inspection entails. This changes the CTS by moving the details of the shield building inspection to the TS Bases. The removal of these details, which are related to methods of surveillance test performance, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirements for verifying integrity of the shield building. Also, this changes is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to methods of surveillance test performance is being removed from the Technical Specifications.

LA03 CTS 4.6.1.8.d.4 requires verification that each Emergency Gas Treatment System produces a negative pressure within limits in the annulus within 1 minute after a start signal. ITS SR 3.6.7.4 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program. (The change of the requirement to perform the Surveillances ON A STAGGERED TEST BASIS is discussed in DOC L02). Additionally, ITS SR 3.6.7.1 has been added to verify the annulus negative pressure is within limits every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and ITS SR 3.6.7.2 has been added to verify the shield building access door in each access opening is closed every 31 days. (See DOC M01 for the discussion on adding these SRs.) The "12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " and "31 day" Frequencies for these Surveillances have been relocated to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in DISCUSSION OF CHANGES ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 4 of 5 the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA04 CTS 1.30 states, in part, "SHIELD BUILDING INTEGRITY shall ex ist when: c. The sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) is OPERABLE.

ITS 3.6.7 states "The shield building shall be OPERABLE." This changes the CTS by moving the reference to penetration sealing mechanism requirements to the Bases.

The removal of these details, which are related to system operation, from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for the shield building to be OPERABLE and the relocated material describes aspects of OPERABILITY. In addition, the ITS retains the requirement to perform a shield building annulus drawdown test, which would provide verification that the penetration sealing mechanisms are OPERABLE. Also, this change is acceptable, because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES

L01 CTS 3.6.1.7 does not state what action to take if the shield building is inoperable while in MODE 1, 2, 3, or 4; it only includes a requirement that the shield building be restored to OPERABLE status prior to increasing Reactor Coolant System temperature above 200°F (i.e., MODE 4). Therefore, entry into CTS 3.0.3 is required, if CTS 3.6.1.7 is not met in MODE 1, 2, 3, or 4. CTS 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to prepare for a shutdown and requires the unit to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

ITS 3.6.7 ACTION A provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the shield building to OPERABLE status prior to requiring a unit shutdown. This changes the CTS by providing an explicit ACTION to allow time to restore an inoperable shield building to OPERABLE status prior to requiring a unit shutdown and changes the time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (as provided in CTS 3.0.3) to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . See DOC A02 for including the ACTIONS within the Specification to shut down the unit upon failure to restore shield building OPERABILITY, rather than deferring to CTS 3.0.3.

The purpose of CTS 3.6.1.7 is to maintain the shield building OPERABLE.

Therefore, when the shield building is not OPERABLE, CTS 3.0.3 results in placing the unit in a condition in which the shield building is not required. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to DISCUSSION OF CHANGES ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 5 of 5 repair inoperable features. This change provides an ACTION that allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the shield building to OPERABLE status. The Required Actions and associated 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time are reasonable considering the limited leakage design of containment and the low probability of DBA occurring during this period. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L02 CTS 4.6.1.8.d.4 requires a drawdown of the shield building annulus by each Emergency Gas Treatment System (EGTS) train to within limits at least once per 18 months. ITS SR 3.6.7.4 requires a drawdown of the shield building annulus to within limits "In accordance with the Surveillance Frequency Control Program." The specified Surveillance Frequency that is being moved to the Surveillance Frequency Control Program is "18 months on a STAGGERED TEST BASIS for each Emergency Gas Treatment System train." This changes the CTS by allowing the drawdown test for each EGTS train to be performed less frequently. Moving the specified Surveillance Frequency to the Surveillance Frequency Control Program is discussed in DOC LA03.

The purpose of CTS 4.6.1.8.d.4 is to verify the integrity of the shield building boundary by ensuring the shield building annulus can be rapidly drawn to a negative pressure of at least 0.5 inches water gauge. Therefore, this is a test of shield building integrity and does not need to be performed every 18 months using each EGTS train. Staggering use of the EGTS trains every 18 months will ensure both trains are capable of performing the test. This change is acceptable because performing the drawdown test using one train of EGTS every 18 months will adequately verify shield building integrity. OPERABILITY of EGTS will be maintained through the application of the requirements of ITS 3.6.10. This change is designated as less restrictive, because the shield building annulus drawdown Surveillance will be performed less frequently with each EGTS train

under the ITS than under the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Shield Building (Dual and Ice Condenser) 3.6.8 Westinghouse STS 3.6.8-1 Rev. 4. CTS 1 7 1SEQUOYAH UNIT 1 Amendment XXX 7 23.6 CONTAINMENT SYSTEMS

3.6.8 Shield Building (Dual and Ice Condenser)

LCO 3.6.8 The shield building shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Shield building inoperable.

A.1 Restore shield building to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 [ Verify annulus negative pressure is

> [5] inches water gauge.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance

with the Surveillance

Frequency Control Program

] 3.6.1.7 A pplicability 7 7 1 3INSERT 1 DOC L01 DOC A02 7 1 4 5 5 DOC M01 3.6.7 Insert Page 3.6.7-1 INSERT 1 --------------------------------------------NOTE-------------------------------------------- The access doors may be opened for normal transit entry and exit. -----------------------------------------------------------------------------------------------

3 1.30.a CTS Shield Building (Dual and Ice Condenser) 3.6.8 Westinghouse STS 3.6.8-2 Rev. 4. CTS 1 7 1SEQUOYAH UNIT 1 Amendment XXX 7 2SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.8.2 Verify one shield building access door in each access opening is closed.

[ 31 days OR In accordance with the Surveillance

Frequency

Control Program

] SR 3.6.8.3 [ Verify shield building structural integrity by performing a visual inspection of the exposed interior and exterior surfaces of the shield building.

During shutdown for SR 3.6.1.1

Type A tests

]

SR 3.6.8.4 Verify the shield building can be maintained at a pressure equal to or more negative than

[-0.5] inch water gauge in the annulus by one Shield Building Air Cleanup System train with final flow

[ ] cfm within [22] seconds after a start signal.

[ [18] months on a STAGGERED TEST BASIS for each Shield Building Air Cleanup System train OR In accordance

with the Surveillance

Frequency Control Program

] 1 5 5 7 7 7 1 4 1 5 60 Emergency Gas Treatment System 4 2the 6 5 4 DOC M01 4.6.1.7 4.6.1.8.d.4 accessible 7

Shield Building (Dual and Ice Condenser) 3.6.8 Westinghouse STS 3.6.8-1 Rev. 4. CTS 1 7 1SEQUOYAH UNIT 2 Amendment XXX 7 23.6 CONTAINMENT SYSTEMS

3.6.8 Shield Building (Dual and Ice Condenser)

LCO 3.6.8 The shield building shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Shield building inoperable.

A.1 Restore shield building to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 [ Verify annulus negative pressure is

> [5] inches water gauge.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance

with the Surveillance

Frequency Control Program

] 3.6.1.7 A pplicability 7 7 1 3INSERT 1 DOC L01 DOC A02 7 1 4 5 5 DOC M01 3.6.7 Insert Page 3.6.7-1 INSERT 1 --------------------------------------------NOTE-------------------------------------------- The access doors may be opened for normal transit entry and exit. -----------------------------------------------------------------------------------------------

3 1.30.a CTS Shield Building (Dual and Ice Condenser) 3.6.8 Westinghouse STS 3.6.8-2 Rev. 4. CTS 1 7 1SEQUOYAH UNIT 2 Amendment XXX 7 2SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.8.2 Verify one shield building access door in each access opening is closed.

[ 31 days OR In accordance with the Surveillance

Frequency

Control Program

] SR 3.6.8.3 [ Verify shield building structural integrity by performing a visual inspection of the exposed interior and exterior surfaces of the shield building.

During shutdown for SR 3.6.1.1

Type A tests

]

SR 3.6.8.4 Verify the shield building can be maintained at a pressure equal to or more negative than

[-0.5] inch water gauge in the annulus by one Shield Building Air Cleanup System train with final flow

[ ] cfm within [22] seconds after a start signal.

[ [18] months on a STAGGERED TEST BASIS for each Shield Building Air Cleanup System train OR In accordance

with the Surveillance

Frequency Control Program

] 1 5 5 7 7 7 1 4 1 5 60 Emergency Gas Treatment System 4 2the 6 5 4 DOC M01 4.6.1.7 4.6.1.8.d.4 accessible 7

JUSTIFICATION FOR DEVIATIONS ITS 3.6.7, SHIELD BUILDING Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The heading and title for ISTS 3.6.8 include the parenthetical expression (Dual and Ice Condenser). This identifying information is not included in the Sequoyah Nuclear (SQN) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specifications to be used as a model for a plant-specific ITS conversion, but serves no purpose in a plant-specific implementation. Therefore, necessary editorial changes were made. In addition, SQN design does not include the Spray Additive System (ISTS 3.6.7). Therefore, ISTS 3.6.7 is not included in the SQN ITS and ISTS 3.6.8 is renumbered as ITS 3.6.7.

2. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. There is no allowance in ISTS 3.6.8 for when a shield building access door is open for normal transit entry and exit, thereby requiring entry into Condition A. Therefore, an exception to the requirement that the access opening doors be closed is made to allow for normal transit entry and exit. The basis of this exception is the assumption that the transit time during which a door is open will be short (i.e., shorter than the Completion Time for Condition A). This change is consistent with the current licensing basis as defined in CTS 1.30, definition of SHIELD BUILDING INTEGRITY, which provides this exception to the requirement for the door in each access opening to be closed.

4. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

5. ISTS SR 3.6.8.1, SR 3.6.8.2, and SR 3.6.8.4 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.6.7.1, SR 3.6.7.2, and SR 3.6.7.4 under the Surveillance Frequency Control Program.

6. ISTS SR 3.6.8.2 requires verification that "one" access door in each shield building access opening is closed. However, SQN design consists of one door for each shield building access opening. Therefore, the Surveillance is changed to verify "the" shield building access door in each access opening closed, thereby reflecting the plant-specific design.

7. ISTS SR 3.6.8.4 requires verification that the Shield Building can be maintained at a negative pressure relative to the annulus by one train within a specified time and flow rate after a start signal. ITS SR 3.6.7.4 will require a similar test, but will not specify a flow rate for the EGTS train. The current licensing basis for this acceptance criteria is derived from the license amendment requested by TVA and approved by the NRC on December 23, 1982.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-1 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 1 B 3.6 CONTAINMENT SYSTEMS

B 3.6.8 Shield Building (Dual and Ice Condenser)

BASES BACKGROUND The shield building is a concrete structure that surrounds the steel containment vessel. Between the containment vessel and the shield building inner wall is an annular space that collects containment leakage that may occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of the steel

containment vessel.

The Shield Building Air Cleanup System (SBACS) establishes a negative pressure in the annulus between the shield building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment. The shield building is required to be OPERABLE to ensure retention of containment leakage and proper operation of the SBACS. APPLICABLE The design basis for shield building OPERABILITY is a LOCA. SAFETY Maintaining shield building OPERABILITY ensures that the release of ANALYSES radioactive material from the containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses.

The shield building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Shield building OPERABILITY must be maintained to ensure proper operation of the SBACS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.

APPLICABILITY Maintaining shield building OPERABILITY prevents leakage of radioactive material from the shield building. Radioactive material may enter the shield building from the containment following a LOCA. Therefore, shield building OPERABILITY is required in MODES 1, 2, 3, and 4 when a steam line break, LOCA, or rod ejection accident could release radioactive material to the containment atmosphere.

In MODES 5 and 6, the probability and consequences of these events are

low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, shield building OPERABILITY is not required in MODE 5 or 6.

7 1 2Emergency Gas Treatment System (EGTS)

EGTS EGTS INSERT 2 2 2INSERT 1 INSERT 1 is a system common to Units 1 and 2 consisting of two subsystems: a.annulus vacuum control subsystem, and b.air cleanup subsystem.The annulus vacuum control subsystem is used during normal operation to establish and maintain a negative pressure in the annulus space. The annulus vacuum control subsystem does not perform any safety function.

The air cleanup subsystem operates during a LOCA to establish and maintain a negative annulus pressure of at least 0.5 inches water gauge. Filters in the subsystem then control the release of radioactive contaminates to the environment. The EGTS air cleanup subsystem OPERABILITY requirements are specified in LCO 3.6.10, "Emergency Gas Treatment System (EGTS) Air Cleanup Subsystem

." INSERT 1 2 The isolation devices for the penetrations in the shield building boundary are a part of the shield building leak tight barrier. To maintain the shield building boundary leak tight, the sealing mechanism associated with each penetration (e.g., welds, bellows, or O

-rings) are required to be OPERABLE.

Access to the annulus area of the shield building is provided via the reactor building access room door and the water tight annulus access door located on 690 ft. elevation. During normal operation, these doors provide personnel and equipment access to the shield building annulus area and are equipped with electrical interlocks to assure that one door is always closed

. Access to the annulus area is also provided via equipment hatches, which are typically not used during plant operation.

INSERT 2 3 To maintain a leak tight barrier in the shield building: the door in each access opening must be closed except when the access opening is being used for normal transit entry and exit; and the sealing mechanisms associated with each penetration (e.g., welds, bellows, or O

-rings) are OPERABLE.The LCO is modified by a Note to allow the shield building access doors to be opened to allow normal transit entry and exit. The basis of this exception is the assumption that, for normal transit, the time during which a door is open will be short (i.e., shorter than the Completion Time for Condition A).

2 7 2 Insert Page B 3.6.7-1 Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-2 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 1 BASES

ACTIONS A.1

In the event shield building OPERABILITY is not maintained, shield building OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probability of a Design Basis Accident occurring during this time period.

B.1 and B.2

If the shield building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE

[ SR 3.6.8.1 REQUIREMENTS Verifying that shield building annulus negative pressure is within limit ensures that operation remains within the limit assumed in the containment analysis.

[ The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed considering operating experience related to shield building annulus pressure variations and pressure instrument drift during the applicable MODES. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ] 7 1 4 5 6 Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-3 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 1 BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.8.2 Maintaining shield building OPERABILITY requires verifying one door in the access opening closed.

[An access opening may contain one inner and one outer door, or in some cases, shield building access openings are shared such that a shield building barrier may have multiple inner or multiple outer doors. The intent is to not breach the shield building boundary at any time when the shield building boundary is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all time s.] However, all shield building access doors are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening. [ The 31 day Frequency of this SR is based on engineering judgment and is considered adequate in view of the other indications of door status that are available to the operator.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

--REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] [ SR 3.6.8.3 This SR would give advance indication of gross deterioration of the concrete structural integrity of the shield building. The Frequency of this SR is the same as that of SR 3.6.1.1. The verification is done during shutdown.

]

7 1 4 5 6 7 1 4 4 7 sthe 3A visual inspection of the accessible shield building interior and exterior surfaces and verification that no apparent changes in the concrete surface appearance or other abnormal degradation will 8

Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-4 Rev. 4.0 1 7SEQUOYAH UNIT 1 7 1 2Revision XXX BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.8.4 The Shield Building Air Cleanup System produces a negative pressure to prevent leakage from the building. SR 3.6.

8.4 verifies that the shield building can be rapidly drawn down to

[-0.5] inch water gauge in the annulus. This test is used to ensure shield building boundary integrity. Establishment of this pressure is confirmed by SR 3.6.

8.4, which demonstrates that the shield building can be drawn down to [-0.5] inches of vacuum water gauge in the annulus [22] seconds using one Shield Building Air Cleanup System train. The time limit ensures that no significant quantity of radioactive material leaks from the shield building prior to developing the negative pressure. Since this SR is a shield building boundary integrity test, it does not need to be performed with

each Shield Building Air Cleanup System train. [ The Shield Building Air Cleanup System train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.8.4, either train will perform this test.

] The primary purpose of this SR is to ensure shield building integrity. The secondary purpose of this SR is to ensure that the

Shield Building Air Cleanup System being tested functions as designed. The inoperability of the Shield Building Air Cleanup Syst em train does not necessarily constitute a failure of this Surveillance relative to the shield building OPERABILITY.

[ The 18 month Frequency is based on the need to perform this Surveillance under conditions that apply during a plant outage.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES None.

7 1 2 EGTS 7 1 4 7 1 4 60 EGTS 2 EGTS 2 EGTS train 2 EGTS 5 6 5 Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-1 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 2 B 3.6 CONTAINMENT SYSTEMS

B 3.6.8 Shield Building (Dual and Ice Condenser)

BASES BACKGROUND The shield building is a concrete structure that surrounds the steel containment vessel. Between the containment vessel and the shield building inner wall is an annular space that collects containment leakage that may occur following a loss of coolant accident (LOCA). This space also allows for periodic inspection of the outer surface of the steel

containment vessel.

The Shield Building Air Cleanup System (SBACS) establishes a negative pressure in the annulus between the shield building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment. The shield building is required to be OPERABLE to ensure retention of containment leakage and proper operation of the SBACS. APPLICABLE The design basis for shield building OPERABILITY is a LOCA. SAFETY Maintaining shield building OPERABILITY ensures that the release of ANALYSES radioactive material from the containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses.

The shield building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Shield building OPERABILITY must be maintained to ensure proper operation of the SBACS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analyses.

APPLICABILITY Maintaining shield building OPERABILITY prevents leakage of radioactive material from the shield building. Radioactive material may enter the shield building from the containment following a LOCA. Therefore, shield building OPERABILITY is required in MODES 1, 2, 3, and 4 when a steam line break, LOCA, or rod ejection accident could release radioactive material to the containment atmosphere.

In MODES 5 and 6, the probability and consequences of these events are

low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, shield building OPERABILITY is not required in MODE 5 or 6.

7 1 2Emergency Gas Treatment System (EGTS)

EGTS EGTS INSERT 2 2 2INSERT 1 INSERT 1 is a system common to Units 1 and 2 consisting of two subsystems: a.annulus vacuum control subsystem, and b.air cleanup subsystem.The annulus vacuum control subsystem is used during normal operation to establish and maintain a negative pressure in the annulus space. The annulus vacuum control subsystem does not perform any safety function.

The air cleanup subsystem operates during a LOCA to establish and maintain a negative annulus pressure of at least 0.5 inches water gauge. Filters in the subsystem then control the release of radioactive contaminates to the environment. The EGTS air cleanup subsystem OPERABILITY requirements are specified in LCO 3.6.10, "Emergency Gas Treatment System (EGTS) Air Cleanup Subsystem

." INSERT 1 2 The isolation devices for the penetrations in the shield building boundary are a part of the shield building leak tight barrier. To maintain the shield building boundary leak tight, the sealing mechanism associated with each penetration (e.g., welds, bellows, or O

-rings) are required to be OPERABLE.

Access to the annulus area of the shield building is provided via the reactor building access room door and the water tight annulus access door located on 690 ft. elevation. During normal operation, these doors provide personnel and equipment access to the shield building annulus area and are equipped with electrical interlocks to assure that one door is always closed

. Access to the annulus area is also provided via equipment hatches, which are typically not used during plant operation.

INSERT 2 3 To maintain a leak tight barrier in the shield building: the door in each access opening must be closed except when the access opening is being used for normal transit entry and exit; and the sealing mechanisms associated with each penetration (e.g., welds, bellows, or O

-rings) are OPERABLE.The LCO is modified by a Note to allow the shield building access doors to be opened to allow normal transit entry and exit. The basis of this exception is the assumption that, for normal transit, the time during which a door is open will be short (i.e., shorter than the Completion Time for Condition A).

2 7 2 Insert Page B 3.6.7-1 Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-2 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 2 BASES

ACTIONS A.1

In the event shield building OPERABILITY is not maintained, shield building OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probability of a Design Basis Accident occurring during this time period.

B.1 and B.2

If the shield building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE

[ SR 3.6.8.1 REQUIREMENTS Verifying that shield building annulus negative pressure is within limit ensures that operation remains within the limit assumed in the containment analysis.

[ The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed considering operating experience related to shield building annulus pressure variations and pressure instrument drift during the applicable MODES. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] ] 7 1 4 5 6 Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-3 Rev. 4. 1 7 1 2Revision XXX 7SEQUOYAH UNIT 2 BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.8.2 Maintaining shield building OPERABILITY requires verifying one door in the access opening closed.

[An access opening may contain one inner and one outer door, or in some cases, shield building access openings are shared such that a shield building barrier may have multiple inner or multiple outer doors. The intent is to not breach the shield building boundary at any time when the shield building boundary is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all time s.] However, all shield building access doors are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening. [ The 31 day Frequency of this SR is based on engineering judgment and is considered adequate in view of the other indications of door status that are available to the operator.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

--REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] [ SR 3.6.8.3 This SR would give advance indication of gross deterioration of the concrete structural integrity of the shield building. The Frequency of this SR is the same as that of SR 3.6.1.1. The verification is done during shutdown.

]

7 1 4 5 6 7 1 4 4 7 sthe 3A visual inspection of the accessible shield building interior and exterior surfaces and verification that no apparent changes in the concrete surface appearance or other abnormal degradation will 8

Shield Building (Dual and Ice Condenser

) B 3.6.8 Westinghouse STS B 3.6.8-4 Rev. 4.0 1 7SEQUOYAH UNIT 2 7 1 2Revision XXX BASES