ML17264A408

Proposed Tech Specs 3.9.3,Containment Penetrations Re Use of Roll Up Door & Associated Encl Building for LCO 3.9.3 Requirements

ML17264A408
Person / Time
Site:	Ginna
Issue date:	03/20/1996
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17264A407	List: ML17264A406 ML17264A408
References
NUDOCS 9603220072
Download: ML17264A408 (18)

Text

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

a. The equipment hatch shall be either:

bolted in lace with at least one access door hshoc- ~

~~0~~~ ~c54%u~

prhk ~f 2.

closed, isolated by a closure plate that restricts from containment~< ~

air flow

b. One door in the personnel air lock shall be closed; and C. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

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

2. capable of being closed by an OPERABLE Containment Ventilation Isolation System.

APPLICABILITY: Dur ing CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

'I A: One or'mo're'ontainment A.l Suspend CORE Immediately ALTERATIONS.

penetrations not in

.required status. AND A.2 Suspend movement of Immediately irradiated fuel assemblies within containment.

R.E. Ginna Nuclear Power Plant 3.9-4 Amendment No. 61 9'603220072 960320 PDR ADaCK 0S0002e4 P PDR

~ ~

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4,'his is accomplished by maintaining containment OPERABLE as described in LCO 3.6. 1, "Containment." In MODE 5, there are no accidents of concern which require containment. In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained within the requirements of 10 CFR 100.

Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be bolted in place. Good engineering practice dictates that a minimum of 4 bolts be used to hold the equipment hatch in place and that the bolts be approximately e uall s aced.

As an alternative, the equipment hatch an e isolated by a closure plate that restricts air flow from containment.

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~a5hoa~ne fe'i~ Zp 4 iQxw (continued)

R.E. Ginna Nuclear Power Plant 8 3.9-10 Revision 0

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Containment Penetrations B 3.9.3 BASES BACKGROUND The containment equipment and personnel air locks, which are (continued) also part of the containment pressure boundary, provide a means for personnel access during HODES 1, 2, 3, and 4 in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of plant shutdown when containment closure is not required, the door interlock meehan'ism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed in the personnel and equipment hatch (unless the equipment hatch is isolated by a ar 4aoc-

~~O~p o Q.

closure plate .

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

The Containment Purge and Exhaust System includes two subsystems. The Shutdown Purge System includes a 36 inch purge penetration and a 36 inch exhaust penetration. The second subsystem, a Hini-Purge System, includes a 6 inch purge penetration and a 6 inch exhaust penetration. During HODES 1, 2, 3, and 4, the shutdown purge and exhaust penetrations are isolated by a blind flange with two 0-rings that provide the necessary boundary. The two air operated valves in. each of the two mini-purge penetrations can be opened intermittently, but are closed automatically by the Containment Ventilation Isolation Instrumentation System.

Neither of the subsystems is subject to a Specification in HODE 5.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-11 Revision 0

Containment Penetrations B 3.9.3 BASES

'BACKGROUND '

In MODE 6, large air exchangers are used to support

'continued) refueling operations. The normal 36 inch Shutdown Purge System is used for this purpose, and each air operated valve is closed by the Containment Ventilation Isolation Instrumentation in accordance with LCO 3.3.5, "Containment Ventilation Isolation Instrumentation."

The Mini-Purge System also remains operational in MODE 6, and all four valves are also closed by the Containment Ventilation Isolation Instrumentation.

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

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

APPLICABLE During CORE ALTERATIONS or movement of irradiated fuel SAFETY ANALYSES assemblies within containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents, analyzed using the criteria of Reference 2, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Cavity Mater Level,"

and the minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are within the guideline values specified in 10 CFR 100. Standard Review Plan (SRP),

Section 15.7.4, Rev. 1 (Ref. 2), requires containment closure even though this is not an assumption of the accident analyses. The acceptance limits for offsite radiation exposure is 96 rem (Ref. 3).

Containment penetrations satisfy Criterion 3 of. the NRC Policy Statement since these are assumed in the SRP.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-12 Revision 0

Containment Penetrations 8 3.9.3 BASES (continued)

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

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and exhaust penetrations. For the OPERABLE containment purge and exhaust penetrations, this LCO ensures that at least one valve in each of these penetrations is isolable by the Containment Ventilation Isolation System.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is when there is a potential for a fuel handling accident; In MODES I, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6. 1. In MODES 5 and 6, when CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for,a fuel handling accident does not exist. Therefore, under these conditions, no requirements are placed on containment penetration status.

ACTIONS A.l and A.2 If the containment equipment hatch (or its closure plate ,

air lock doors, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not, in the required status, including the Containment Ventilation Isolation System not capable of automatic actuation when the purge and exhaust valves are open, the plant must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance

'of these actions shall not preclude completion of movement of a co'mponent to a safe position.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-13 Revision 0

Containment Penetrations 8 3.9.3 BASES (continued)

SURVEILLANCE SR 3.9.3.1 RE(UIREHENTS This SR demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are not blocked or otherwise prevented from closing (e.g., solenoid unable to vent).

The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. As such, this Surveillance ensures that a postulated fuel handling accident that releases fission product radioactivity within the containment will not result in a release of fission product radioactivity to the environment.

SR 3.9.3.2 This SR demonstrates that each containment purge and exhaust valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal. The 24 month Frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.5, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a COT every 92 days to ensure the channel OPERABILITY during refueling operations. Every 24 months an ACTUATION LOGIC TEST and CHANNEL CALIBRATION is performed.

These Surveillances will ensur'e that the valves are capable of closing after a postulated fuel handling accident to

'limit a release of fission product radioactivity from the containment.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-14 Revision 0

Containment Penetrations B 3.9.3 BASES (continued)

REFERENCES 1. UFSAR, Section 15.7.

2. NUREG-800, Section 15.7.4, Rev. 1, July 1981.

3. Letter from D. M. Crutchfi el d, NRC, to J. Mai er, RGE E,

Subject:

"Fuel Handling Accident Inside Containment,"

dated October 7, 1981.

R.E. Ginna Nuclear Power Plant B 3.9-15 Revision 0

Attachment III Proposed Technical Specifications Included pages (note that not all pages are changed):

3.9-4 3.9-5 B3.9-10 B3.9-11 B3.9-12 B3.9-13 B3.9-14 B3.9-15

tainment Penetrations 3.9.3

3. 9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch shall be either:

1. bolted in place with at least one access door closed,

2. isolated by a closure plate that restricts air flow from containment, or

3. isolated by a roll up door and enclosure building;

b. One door in the personnel air lock shall be closed; and C. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

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

2. capable of being closed by an OPERABLE Containment Ventilation Isolation System.

APPLICABILITY: During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

R.E. Ginna Nuclear Power Plant 3.9-1 Amendment No. g

tainment Penetrations 3.9.3 ACTIONS CONDITION RE(UIRED ACTION COMPLETION TIME A. One or more A. I Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status. AND A.2 Suspend movement of Immediately irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FRE(UENCY SR 3.9.3.1 Verify each required containment 7 days ~

penetration is in the required status.

SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

R.E. Ginna Nuclear Power Plant 3.9-2 Amendment No. g

tainment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met; In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6. 1, "Containment." In MODE 5, there are no accidents of concern which require containment. In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fissi'on product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained within the requirements of 10 CFR 100.

Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be bolted in place. Good engineering practice dictates that a minimum of 4 bolts be used to hold the equipment hatch in place and that the bolts be approximately equally spaced.

As an alternative, the equipment hatch opening can be isolated by a closure plate that restricts air flow from containment or by an installed roll up door and enclosure building.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-10 Revision 0

V

ntainment Penetra'tions B 3.9.3 BASES BACKGROUND The containment equipment and personnel air locks, which are (continued) also part of the containment pressure boundary, provide a means for personnel access during HODES 1, 2, 3, and 4 in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of plant shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed in the personnel and equipment hatch (unless the equipment hatch is isolated by a closure plate or the roll up door and associated enclosure building).

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

The Containment Purge and Exhaust System includes two subsystems. The Shutdown Purge System includes a 36 inch purge penetration and a 36 inch exhaust penetr ation. The second subsystem, a Hini-Purge System, includes a 6 inch purge penetration and a 6 inch exhaust penetration. During HODES 1, 2, 3, and 4, the shutdown purge and exhaust penetrations are isolated by a blind flange with two 0-rings that provide the necessary boundary. The two air operated valves in each of the two mini-purge penetrations can be opened intermittently, but are closed automatically by the Containment Ventilation Isolation Instrumentation System.

Neither of the subsystems is subject to a Specification in HODE 5.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-11 Revision 0

tainment Penetrations B 3.9.3 BASES BACKGROUND In MODE 6, large air exchangers are used to support (continued) refueling operations. The normal 36 inch Shutdown Purge System is used for this purpose, and each air operated valve is closed by the Containment Ventilation Isolation Instrumentation in accordance with LCO 3.3.5, "Containment Ventilation Isolation Instrumentation."

The Mini-Purge System also remains operational in MODE 6, and all four valves are also closed by the Containment Ventilation Isolation Instrumentation.

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

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

APPLICABLE During CORE ALTERATIONS or movement of irradiated fuel SAFETY ANALYSES assemblies within containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents, analyzed using the criteria of Reference 2, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Cavity Water Level,"

and the minimum decay'time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are within the guideline values specified in 10 CFR 100. Standard Review Plan (SRP),

Section 15.7.4, Rev. 1 (Ref. 2), requires containment closure even though this is not an assumption of the accident analyses. The acceptance limits for offsite radiation exposure is 96 rem (Ref. 3).

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement s'ince these are assumed in the SRP.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-12 Revision 0

tainment Penetrations 8 3.9.3 BASES (continued)

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

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and exhaust penetrations. For the OPERABLE containment purge and exhaust penetrations, this LCO ensures that at least one valve in each of these penetrations is isolable by the Containment Ventilation Isolation System.

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

ACTIONS A. 1 and A.2 If the containment equipment hatch (or its closure plate or roll up door and associated enclosure building), air lock doors, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the Containment Ventilation Isolation System not capable of automatic actuation when the purge and exhaust valves are open, the plant must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

(continued)

R.E. Ginna Nuclear Power Plant B 3.9-13 Revision 0

tainment Penetrations B 3.9.3 BASES (continued)

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This SR demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust val,ves will demonstrate that the valves are not blocked or otherwise prevented from closing (e.g., solenoid unable to vent).

The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. As such, this Surveillance ensures that a postulated fuel handling accident that releases "fission product radioactivity within the containment will not result in a release of fission product radioactivity to the environment.

SR 3.9.3.2 This SR demonstrates that each containment purge and exhaust valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal. 'The 24 month Frequency maintains consistency with other similar instrumentation and valve testing requirements. In LCO 3.3.5, the Containment Ventilation Isolation instrumentation requires a CHANNEL CHECK every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a COT every 92 days to ensure the channel OPERABILITY during refueling operations. Every 24 months an ACTUATION LOGIC TEST and CHANNEL CALIBRATION is performed.

These Sur'veillances will ensure that the valves are capable of closing after a postulated fuel handling accident to limit a release of fission product radioactivity from the containment.

(continued)

R.E. Ginna Nuclear Power Pl'ant B 3.9-14 Revision 0

ntainment Penetrations B 3.9.3 BASES (continued)

REFERENCES 1. UFS)R, Section 15.7.

2. NUREG-800, Section 15.7.4, Rev. 1, July 1981.

3. Letter from D. H. Crutchfield, NRC, to J. Haier, RG&E,

Subject:

"Fuel Handling Accident Inside Containment,"

dated October 7, 1981.

R.E. Ginna Nuclear Power Plant B 3.9-15 Revision 0