ML18152A175

Proposed TS Change Re Containment Isolation Requirements

ML18152A175
Person / Time
Site:	Surry
Issue date:	06/01/1992
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18152A176	List: ML18152A175 ML18153D030
References
NUDOCS 9206120198
Download: ML18152A175 (27)

Text

ATTACHMENT 1 SURRY POWER STATION PROPOSED TECHNICAL SPECIFICATION CHANGE

....... FOR -CONTAINMENT ISOLATION REQUIREMENTS

( 9206120198 920601 PDR ADOC'K 05000280 p . . PDR

e TS 1.0-4

2. CHANNEL FUNCTIONAL TEST Injection of a*simulated signal into an analog channel as *Close to the sensor as practicable or makeup of the logic combinations in a logic channel to verify that it is operable, including alarm and/or trip initiating action.

3. CHANNEL CALIBRATION Adjustment of channel output such that it responds, with acceptable range and accuracy, to known values of the parameter which the channel measures. Calibration shall encompass the entire channel, including equipment action, alarm, or trip and shall be deemed to include the CHANNEL FUNCTIONAL TEST.

4. SOURCE CHECK A source check shall be a qualitative assessment of radiation monitor response when the channel sensor is exposed to a radioactive source .

. H. CONTAINMENT INTEGRITY Containment integrity shall exist when:

a. The penetrations required to be closed during accident conditions are either:

1) Capable of being closed by an OPERABLE containment automatic isolation valve system, or Amendment Nos.

TS 1.0-5

2) . Closed by at least one-closed manual valve, blind flange, .or

• deactivated automatic'valve-secured in* its closed *position except as provided in Specification 3.8.C. Non-automatic or deactivated automatic containment isolation valves may be opened intermittently for operational activities provided that the valves are under administrative control and are capable of being closed immediately, if required.

b. The equipment access hatch is closed and sealed,

c. Each airlock is OPERABLE except as provided in Specification

. .3.8.B,

d. The containment leakage rates are within the limits of Specification 4.4, and

e. The sealing mechanism associated with each penetration (e.g.,

welds, bellows, or 0-rings) is OPERABLE.

I. REPORTABLE EVENT A reportable event shall be any of those conditions specified in Section

50. 73 to 10 CFR Part 50.

Amendment Nos.

TS 3.8-1 3.8 CONTAINMENT Applicability Applies to the integrity and operating pressure of the reactor containment.

Objective To define the limiting operating conditions of the reactor containment.

Specification A. CONTAINMENT INTEGRITY

1. ;CONTAINMENT INTEGRITY, as defined in TS Section 1.0, shall be maintained whenever the Reactor Coolant System temperature exceeds 200°F.

a. Without CONTAINMENT INTEGRITY, re-establish CONTAINMENT INTEGRITY in accordance with the definition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

b. Otherwise, be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2. The inside and outside isolation valves in the Containment Ventilation Purge System shall be locked, sealed, or otherwise secured closed whenever the Reactor Coolant System temperature exceeds 200°F.

3. The inside and outside isolation valves in the containment vacuum ejector suction line shall be locked, sealed, or otherwise secured closed whenever the Reactor Coolant System temperature exceeds 200°F.

Amendment Nos.

e TS 3.8-2 B. Containment Airlocks

1. Each containment airlock shall be OPERABLE with both doors of the personnel airlock closed except when the airlock is being used for normal transit entry and exit through the containment, then at

• least one *airlock door shall be closed.

a. With one airlock or associated interlock inoperable, maintain the OPERABLE door closed and either restore the inoperable door to OPERABLE status or lock closed the OPERABLE door within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. If the personnel airlock inner door or interlock is inoperable, the outer personnel airlock door may be opened for repair and retest of the inner door. If the inoperability is due to the personnel airlock inner door seal exceeding the leakage test acceptance criteria, the outer personnel airlock door may be opened for a period of time not to exceed fifteen minutes with an annual cumulative time not to exceed one hour per year for repair and retest of the inner door seal.

c. Otherwise, be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

C. Containment Isolation Valves

1. Containment isolation valves shall be OPERABLE.t With one or more isolation valve(s) inoperable, maintain at least one isolation valve OPERABLEt in each affected penetration that is open and either:

a. Restore the inoperable valve(s) to OPERABLE status. within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or

b. Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured in the isolation position, or t Non-automatic or deactivated automatic containment isolation valves may be opened on an intermittent basis under administrative control.

Amendment Nos.

e TS 3.8-3

c. Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at

.least one closed manual valve or blind flange, or

d. Otherwise, place the unit in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

D. Internal Pressure

1. Containment air partial pressure shall be maintained within the acceptable operation range as identified in Figure 3.8-1 whenever the Reactor Coolant System temperature and pressure exceed 450°F and 350 psig, respectively.

a. With the containment air partial pressure outside the acceptable operation range, restore the air partial pressure to within acceptable limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Basis CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. These restrictions, in conjunction with the allowed leakage, will limit the site boundary radiation dose to within the limits of 10 CFR 100 during accident conditions.

The operability of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization

. of the .. containment. The opening .of. manual" or. deactivated. automatic containment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with the control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and Amendment Nos.

e e TS 3.8-4 (3) assuring that environmental conditions will not preclude access to close the valves and 4) that this administrative or manual action will prevent the release of radioactivity outside the containment.

The Reactor Coolant System *temperature and pressure being *below 350°F and 450 psig, respectively, ensures that no significant amount of flashing steam will be formed and hence that there would be no significant pressure buildup in the containment if there is a loss-of-coolant accident. Therefore, the containment internal pressure is not required to be subatmospheric prior to exceeding 350°F and 450 psig.

The allowable value for the containment air partial pressure is presented in TS Figure 3.8-1. for service water temperatures from 25 to 92°F. The allowable value varies as shown in TS Figure 3.8-1 for a given containment average temperature. The RWST water shall have a maximum temperature of 45°F.

The horizontal limit lines in TS Figure 3.8-1 are based on LOCA peak calculated pressure criteria, and the sloped line is based on LOCA subatmospheric peak pressure criteria.

The curve shall be interpreted as follows:

The horizontal limit line designates the allowable air partial pressure value for the given average containment temperature. The horizontal limit line applies for service water temperatures from 25°F to the sloped line intersection value (maximum service water temperature).

From TS Figure 3.8-1, if the containment average temperature is 112°F and the service water temperature is less than or equal to 83°F, the allowable air partial

- pressure value shall be less than or equal to 9.65 psia. If the average containment temperature is 116°F and the service water temperature is less than or equal to 88°F, the allowable air partial pressure value shall be less than or equal to 9.35 psia. These horizontal limit lines are a result of the higher allowable initial containment average temperatures and the analysis of the pump suction break.

Amendment Nos.

TS 3.8-5 If the containment air partial pressure rises to a point above the allowable value the reactor shall be brought to the HOT SHUTDOWN condition. If a LOCA occurs at the time the containment air partial pressure *is at the maximum allowable value, the maximum containment pressure will be less than design

• • *- pressure (45 psig),* the containment will depressurize in less than 1- hour, and

• the maximum subatmospheric peak pressure will be less than 0.0 psig.

If the containment air parti_al pressure cannot be maintained greater than or equal to 9.0 psia, the reactor shall be brought to the HOT SHUTDOWN condition. The shell and dome plate liner of the containment are capable of withstanding an internal pressure as low as 3 psia, and the bottom mat liner is capable of withstanding an internal pressure as low as 8 psia.

References UFSAR Section 4.3.2 Reactor Coolant Pump UFSAR Section 5.2 Containment Isolation UFSAR Section 5.2.1 Design Bases UFSAR Section 5.5.2 Isolation Design UFSAR Section 6.3.2 Containment Vacuum System Amendment Nos.

e e TS Figure 3.8-1 ALLOWABLE AIR PARTIAL PRESSURE SURRY POWER STATION UNITS 1 AND 2

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FIGURE NOTATION TC - Containment average temperature FIGURE NOTES

1. Refueling Water Storage Tank temperature s 45°F.

2. Allowable operating air partial pressure in the containment is a function of service water temperature.

3. Horizontal lines designate allowable air partial pressure per given containment average temperature.

4. Each containment temperature line is a maximum for the given air partial pressure.

Amendment Nos.

TS 3.10-1 3.10 REFUELING Applicability Applies to operating limitations during REFUELING OPERATIONS.

Objective To assure that no accident could occur during REFUELING OPERATIONS that would affect public health and safety.

Specification A. During REFUELING OPERATIONS the following conditions are satisfied: I

1. The equipment access hatch and at least one door in the personnel airlock shall be properly closed. For those penetrations which provide a direct path from containment atmosphere to the outside atmosphere, the automatic containment isolation valves shall be operable or the penetration shall be closed by a valve, blind flange, or equivalent.

2. The Containment Ventilation Purge System and the area and airborne radiation monitors which initiate isolation of this system shall be tested and verified to be operable immediately prior to REFUELING OPERATIONS.

Amendments Nos.

TS 3.10-5 Basis Detailed instructions, the above specified precautions, and the design .of the fuel handling equipment, which .incorporates .built-in .interlocks and safety features, provide assurance that an accident, which would result in a hazard to public health and safety,, will not occur during unit REFUELING OPERATIONS. I When no change is being made in core geometry, one neutron detector is sufficient to monitor the core and permits maintenance of the out-of-function instrumentation. Continuous monitoring of radiation levels and neutron flux provides immediate indication of an unsafe condition.

Potential escape paths for fission product radioactivity within containment are required to be closed or capable of closure to prevent the release to the environment. However, since there is no potential for significant containment pressurization during refueling, the Appendix J leakage criteria and tests are not applicable.

The containment equipment access hatch, which is part of the containment pressure boundary, provides a meE!_ns for moving large equipment and components into and out of the containment. During REFUELING OPERATIONS, the equipment hatch is held in place with at least four approximately equally spaced bolts.

The containment airlocks, which are also part of the containment pressure boundary, provide a means for personnel access during periods when

.CONTAINMENT INTEGRITY is required. Each airlock has a door at both ends.

The doors are normally interlocked to prevent simultaneous opening. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors to remain open for extended periods when frequent containment entry is necessary. During REFUELING OPERATIONS, containment .closure. is .required. Therefore, the door interlock mechanism may remain disabled, but one airlock door must remain closed. The emergency escape airlock (trunk) may be removed from the equipment access hatch during REFUELING OPERATIONS, provided the penetration is closed by an approved method which provides a temporary, atmospheric pressure ventilation barrier.

Amendment Nos.

TS 3.10-6 Containment high radiation levels and high airborne activity levels automatically stop and isolate the Containment Ventilation Purge System. The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated by at least one barrier during REFUELING OPERATIONS. Isolation may be achieved by an OPERABLE automatic isolation valve, a closed valve, a blind flange, or by an equivalent isolation method. Equivalent isolation methods must be evaluated and may include use of a material that can provide a temporary, atmospheric pressure ventilation barrier.

The fuel building ventilation exhaust is diverted through charcoal filters whenever refueling is in progress. At least one flow path is required for cooling and mixing the coolant contained in the reactor vessel so as to maintain a uniform boron concentration and to remove residual heat.

During refueling, the reactor refueling water cavity is filled with approximately 220,000 gal of water borated to at least 2,300 ppm boron. The boron concentration of this water, established by Specification 3.1 O.A.9, is sufficient to maintain the reactor subcritical by at least 5 % ~k/k in the COLD SHUTDOWN I condition with all control rod assemblies inserted. This includes a 1% ~k/k and a 50 ppm boron concentration allowance for uncertainty. This concentration is also sufficient to maintain the core subcritical with no control rod assemblies inserted into the reactor. Checks are performed during the reload design and safety analysis process to ensure the K-effective is equal to or less than 0.95 for each core. Periodic checks of refueling water boron concentration assure the proper shutdown margin. Specification 3.1 O.A.1 O allows the Control Room Operator to inform the manipulator operator of any impending unsafe condition detected from the main control board indicators during fuel movement.

In addition to the above safeguards, interlocks are used during refueling to assure safe handling of the fuel assemblies. An excess weight interlock is provided on the lifting hoist to prevent movement of more than one fuel assembly at a time. The spent fuel transfer mechanism can accommodate only one fuel assembly at a time.

Amendment Nos.

,. l TS 3.10-7 Upon each completion of core loading and installation of the reactor vessel.

head, specific mechanical and electricaltests _wilLbe performed prior to initial criticality.

The fuel handling accident has been analyzed based on the activity that could be released from fuel rod gaps of 204 rods of the highest power assembly* with a 100-hour decay period following power operation at 2550 MWt for 23,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. The requirements detailed in Specification 3.1 O provide assurance that refueling unit conditions conform to the operating conditions assumed in the accident analysis.

Detailed procedures and checks insure that fuel assemblies are loaded in the proper locations in the core. As an additional check, the movable incore detector system will be used to verify proper power distribution. This system is capable of revealing any assembly enrichment error or loading error which could cause power shapes to be peaked in excess of design value.

References UFSAR Section 5.2 Containment Isolation UFSAR Section 6.3 Consequence Limiting Safeguards UFSAR Section 9.12 Fuel Handling System UFSAR Section 11.3 Radiation Protection UFSAR Section 13.3 Table 13.3-1 UFSAR Section 14.4.1 Fuel Handling Accidents UFSAR Supplement: Volume I: Question 3.2

• Fuel rod gas activity from 204 rods of the highest power 15 x 15 assembly is greater than fuel rod gap activity from 264 rods of the highest power 17 x 17 demonstration assembly.

Amendment Nos.

,, l TS 4.1-1 b F. _ Containment Ventilation Purge SystemJsolation valves:

.1. The outside. Containment Ventilation -Purge System isolation valves and the isolation valve in the containment vacuum ejector .suction line outside containment shall be determined locked, sealed, or otherwise secured in the closed position at least once per 31 days.

2. The inside Containment Ventilation Purge System isolation valves and the isolation valve in the containment vacuum ejector suction line inside containment shall be verified locked, sealed, or otherwise secured in the closed position each COLD SHUTDOWN, but not required to be verified more than once per 92 days.

G. Verify that each containment penetration not capable of being closed by OPERABLE automatic isolation valves and required to be closed during accident conditions is closed by manual valves, blind flanges, or deactivated automatic valves secured* in the closed position at least once per 31 days. Valves, blind flanges, and deactivated automatic or manual valves located inside containment which are locked, sealed, or otherwise secured in the closed position shall be verified closed during each COLD SHUTDOWN, but not required to be verified more than once per 92 days.

• Non-automatic or deactivated automatic valves may be opened on an intermittent basis under administrative control.

Amendment Nos.

\.._

ATTACHMENT 2 SURRY POWER STATION DISCUSSION OF CHANGE AND CONTAINMENT ISOLATION REQUIREMENTS SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

j 11 J PROPOSED TECHNICAL SPECIFICATION CHANGE CONTAINMENT ISOLATION AND INTEGRITY INTRODUCTION The definition of and requirements for containment integrity are being. clarified to eliminate potential interpretation difficulties by more closely addressing the terminology and format of NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," Revision 4. Limiting Conditions for Operation, Action Statements, and Surveillance Requirements are being included to provide specific directions for any breach of containment integrity as well as modified Action Statements for containment air partial pressure outside the allowable range.

Redundant requirements are being removed. In addition, the containment isolation

• • valve tables are being eliminated in accordance with Generic Letter 91-08, "Removal of Component Lists From Technical Specifications."

BACKGROUND The existing Technical Specifications' definition of containment integrity requires all automatic containment isolation valves to be operable or secured in their closed position if inoperable. When a containment isolation valve becomes inoperable under the existing definition, the inoperable valve can not be opened for maintenance or tested without being considered a breach of containment integrity. In addition, the existing Technical Specifications do not provide a specific Action Statement for breaches of containment integrity. Therefore, entry into TS 3.0.1 must be used when a breach of containment integrity occurs. TS 3.0.1 requires the unit to be placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

TS 3.8.A.5 and 3.8.A.6, which require containment integrity 1) when the reactor head is unbolted and the shutdown margin is less than 5%~k/k and 2) during positive reactivity additions by rod drive motion or boron dilutions, are being eliminated as unnecessary. Other Technical Specification requirements, specifically Sections 1.0 -

Definitions, 3.2 - Chemical and Volume Control System, 3.1 O - Refueling, and 3.12 -

Control Rods and Power Distribution, provide specific controls for shutdown margin and reactivity additions to maintain plant operations within analyzed bounds.

The Action Statements associated with containment air partial pressure outside the allowable range are being changed to limit plant operation to one hour with the air partial pressure outside the analyzed limits .

. The containment isolation valve tables in Section 3.8 require updating by. license amendment after a containment penetration's isolation configuration has been modified. This proposed Technical Specification change will eliminate this requirement by removing the tables from Technical Specifications. The containment penetration's isolation configuration is documented in the UFSAR and in station procedures.

Section 3.8 is being reformatted to provide a more logical order for the requirements of containment integrity and the associated Action Statements. The Action Statement for the Containment Ventilation Purge System isolation valves is being changed to require the valves to be locked or secured when the Reactor Coolant System exceeds 200°F.

Section 3.1 O is being changed to clarify the requirements for containment isolation during refueling operations. A description of a closed containment is being included in the basis section.

Surveillance requirements for inoperable and nonautomatic containment isolation valves are being established consistent with NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," Revision 4.

DESCRIPTION OF CHANGE Sections 1.0 - Definitions and 3.8 - Containment of the Technical Specifications are being modified to establish the appropriate operational restrictions for breaches of containment integrity and inoperable isolation devices.

• The definition of Containment Integrity (Section .1.H) is being changed to conform to-the definition in Standard Technical Specifications. This change will permit a penetration to be considered closed (isolable) by at least one closed manual valve, blind flange, or deactivated automatic valve secured in the closed position. The definition change in conjunction with the Action Statements will permit maintenance on inoperable containment isolation valves without it being considered a breach of containment integrity.

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• TS 3.8.A.5 and 3.8.A.6, which require containment integrity 1) when the reactor head is unbolted and the shutdown margin is less than 5%Ak/k and 2) during positive reactivity additions by rod drive motion or boron dilutions, are being removed. Positive reactivity accidents in cold shutdown and refueling include

1) an inadvertent boron dilution accident which is precluded by isolating unborated water sources in accordance with Technical Specification 3.2 and 2) an uncontrolled rod withdrawal from a subcritical condition which is automatically terminated by source range high neutron flux trip prior to challenging fuel cladding integrity. In refueling shutdown, Section 3.1 O of the Technical Specifications provides the requirements for containment integrity.

The existing reactivity (shutdown margin) and containment integrity requirements provide adequate control of reactivity additions and containment

• conditions*similar to the Standard Technical Specifications. Removal of the two specific containment integrity requirements is consistent with the Standard Technical Specifications. Standard Technical Specifications require containment integrity in Modes 1, 2, 3, and 4. In Mode 6, during core alterations or irradiated fuel movement, direct release paths are required to be isolated or capable of automatic isolation. There is no requirement for containment integrity for positive reactivity changes made in Mode 5 (cold shutdown).

• Containment integrity is required above 200°F, when the head is unbolted with less than 5%Ak/k shutdown margin, and during positive reactivity additions by rod drive motion or boron dilution. However, if containment integrity is violated during operation (e.g., inoperable automatic isolation valve or an inoperable air lock door) the existing Specifications do not provide Action Statements.

Therefore, the general requirement of TS 3.0.1 must be applied. In the proposed change, Action Statements are being provided to define the allowed outage times and the required operator actions for breaches of containment integrity. These Action Statements are consistent with the Standard Technical Specifications.

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• The Action Statements associated with containment air partial pressure are being changed to eliminate operation for any extended time with the air partial*

pressure outside the limits. The existing Action Statement provides a pressure range (<0.25 psi) before operator action is required.

• The new Action* Statement will provide one hour to restore the air partial .pressure to within the limits or bring the unit to hot shutdown within the next six hours and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

• The notes of Technical Specification Figure 3.8-1 that are also separately specified in the body of Technical Specification 3.8 are being eliminated to avoid potential confusion with redundant requirements. The remaining operating restrictions of Figure 3.8-1 are not being changed.

• , . ::rhis-change .removes the containment isolation valve tables (3.8-1 & 3.8-2) from the Technical Specifications and provides Action Statements for violations of containment integrity. Removing the containment isolation valve tables from Technical Specifications is an administrative change which is consistent with the ongoing Technical Specification Improvement Program and the guidance provided in GL 91-08, "Removal of Component Lists from Technical Specifications." The containment isolation valves are listed in UFSAR and station procedures. The testing requirements for containment isolation devices will remain in Section 4.4 of the Technical Specifications. The test program (1 O CFR 50 App J) for containment is described in UFSAR Section 5.5. The description includes the test techniques used for Type A, B, and C testing and the basis for any NRC exemptions from the Appendix J requirements.

Removing the containment isolation valve tables from Technical Specifications eliminates the need for a Technical Specification change when a containment penetration's isolation configuration is modified. The design of the containment and each penetration's isolation configuration is subject to the design control process which requires a 10 CFR 50:59 evaluation prior to any modification.

The containment testing requirements are controlled by 10 CFR 50 Appendix J and Technical Specification 4.4, and any deviation from these requirements would require approval by the NRC. The UFSAR is updated in accordance with 10 CFR 50.71 while station procedures are subject to the change control provisions of Technical Specification 6.4.

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• The Action Statement for the Containment Ventilation Purge System isolation valves is being changed to require the valves to be locked or secured when the Reactor Coolant System exceeds 200°F.

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• The change to Section 3.1 O clarifies the containment isolation requirements for refueling operations and is consistent with the Standard Technical Specifications.

• The new surveillance requirements in Section 4.1 ensures that inoperable or nonautomatic containment isolation valves are maintained in their correct position.

• A discussion of containment isolation and containment isolation valves is being

. added.to "the Basis section. The discussion includes the controls necessary for intermittent operation of normally closed or sealed isolation valves in accordance with Generic Letter 91-08, "Removal of Component Lists from Technical Specifications."

• Defined words that appear in the affected sections of the Technical Specifications are being capitalized consistent with Standard Technical Specifications. The titles of systems are being changed for consistency. The basis FSAR references are being changed to UFSAR references.

e SAFETY SIGNIFICANCE Changing the definition of containment integrity allows maintenance on an inoperable containment isolation valve while continuing to ensure that each penetration requiring closure-is isolated or capable of being isolated automatically. The proposed change continues to ensure containment integrity is maintained. However, the new definition will allow the opening of inoperable valves for maintenance and testing. Containment leakage is required to be within the limits of Specification 4.4 for operation to continue.

Thus, if containment isolation is challenged and a single failure occurs (i.e., one of two redundant isolation valves or a single failure in the actuation circuitry), radioactive leakage from the containment will not exceed previously analyzed limits. The change does not affect any precursors to previously analyzed accidents or malfunctions and does not create a failure mode which could lead to a new type of accident or

• *malfunction. This change does not affect any safety limit and the margin of safety as described in the Technical Specifications remains unchanged.

Containment integrity is not required to mitigate the consequences of any reactivity transient which is postulated to occur during cold shutdown or refueling shutdown.

Other Technical Specifications, specifically 1.H, 3.1 O.A.9, and 3.12.A.3.c, require that shutdown margin be maintained consistent with the accident analysis assumptions in each operating condition. An inadvertent boron dilution during cold shutdown or refueling shutdown conditions is precluded by isolating unborated water sources in accordance with Technical Specification 3.2.F. An uncontrolled rod withdrawal from a subcritical condition is terminated by the source range high neutron flux trip prior to challenging fuel cladding integrity. Therefore, containment integrity is not necessary for positive reactivity additions via rod motion or boron dilutions during cold shutdown and refueling shutdown conditions or when the reactor head is unbolted and the shutdown margin is less than 5% ~k/k. During both cold shutdown and refueling shutdown conditions, administrative controls require additional shutdown margin beyond the Technical Specification requirements thus providing further conservatism.

• In addition, during reduced inventory operations and when specific penetrations are open, a containment closure team is established to close these penetrations in the event of a loss of RHR. During refueling operations, the Technical Specifications require that direct release paths be isolated or capable of automatic closure ensuring

• that the consequences of a fuel handling accident would be as previously analyzed.

e The new and revised Limiting Condition for Operations and Action Statements for containment integrity and containment air partial pressure as well as the Surveillance Requirement for containment isolation valves are consistent with Standard Technical Specifications. .Providing time to evaluate and repair an inoperable containment barrier or.reestablish the allowable air partial pressure allows for-an orderly evaluation of the inoperability and thereby eliminates the potential for immediate and unnecessary plant shutdowns caused by an immediate entry into TS 3.0.1. The Action Statements are consistent with the Standard Technical Specifications. The containment isolation barriers and valves are not being operated any differently and the clarification of containment isolation does not reduce the level of protection.

Therefore, no new accident precursors are being generated.

The Action Statement for the Containment Ventilation Purge System isolation valves is being changed to require the valves to be locked, sealed, or otherwise secured closed when the Reactor Coolant system temperature exceeds 200°F. The existing Action statement does not permit containment purging when the Reactor Coolant System temperature exceeds 200°F. This change does not affect the operation of the Containment Ventilation Purge system and therfore has no adverse impact on safety.

The administrative changes which include removing the containment isolation valve tables, removing redundant requirements from Figure 3.8-1, capitalizing the defined words, and changing FSAR to UFSAR do not affect the operation of any system, structure, or component.

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.. ,a, *.J e e SIGNIFICANT HAZARDS CONSIDERATION Virginia Electric and Power Company has reviewed the--proposed changes against the

• criteria of 10 CFR 50.92 and has concluded that the changes as proposed do not pose a significant hazards consideration. Specifically,, Sections 1.0 - Definitions, 3.8 - Containment, 3.1 O - Refueling, and 4.1 - Operational Safety Review of the Technical Specifications are being revised. The following changes are being proposed:

• Provide Action Statements for breaches of containment integrity and inoperable isolation devices consistent with Standard Technical Specifications and include additional Surveillance Requirements for containment penetrations.

• Revise the Action Statements for containment air partial pressure to be consistent with the Standard Technical Specifications.

• Modify the definition of containment integrity consistent with Standard Technical Specifications and clarify the isolation requirements for the containment during refueling operations.

• Eliminate the requirement for containment integrity 1) when the reactor head is unbolted and shutdown margin is less than 5%.l\k/k and 2) for positive reactivity additions by rod drive motion or boron dilution.

• Implement several administrative changes.

Remove the Containment Isolation Valve Tables 3.8-1 and 2.

- Eliminate redundant requirements from Figure 3.8-1.

- Capitalize the defined words on the affected pages.

- Change the acronym from FSAR to UFSAR in the reference section.

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Operation of the Surry Power Station in accordance with the proposed changes will not:

1. . Involve a significant increase in the probability .of ,occurrence. or .consequences of any accident previously evaluated.

• Providing Action Statements for breaches of containment integrity does not change the plant design or modify any component, system, or plant operation. The proposed Action Statements and Surveillance Requirements are consistent with the Standard Technical Specifications. The proposed actions, allowed outage times, and surveillance requirements have no effect on the probability of occurrence or the consequences of previously analyzed accidents.

• Revising the Action Statements when the internal containment air partial pressure is outside its operating limits does not change the plant design or modify any component, system, or plant operation. Providing an allowed outage time of one hour in lieu of continued operation with air partial pressure within +0.25 psig of the operating limit is considered to be conservative, in that it prohibits operation for an extended period of time in such a condition. The proposed one hour allowed outage time is consistent with the Standard Technical Specifications. The revised allowed outage time will have no effect on the probability of occurrence or the consequences of previously analyzed accidents. Rather, modifying the basis for the action from a pressure tolerance to allowed outage time is likely to reduce the time the plant can operate in the Action Statement.

• Modifying the definition of containment integrity and clarifying the containment isolation requirements for refueling operations do not impact plant design or change system or plant operation. Therefore, operation with containment integrity established in accordance with the modified definition will not increase the probability of occurrence or consequences of any accident previously evaluated.

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• Eliminating the requirements for containment integrity 1) when the reactor head is unbolted with less than a 5% shutdown margin and 2) for positive reactivity additions due to boron dilution or rod movement in cold shutdown does not impact plant design or change plant or system operation. .Boron

.* dilution and an. uncontrolled rod withdrawal from a subcritical condition are the positive reactivity accidents analyzed i_n cold shutdown and refueling shutdown conditions. The provision of containment integrity has no impact on the probability of either event occurring. An inadvertent boron dilution during cold shutdown or refueling shutdown is precluded by isolating unborated water sources in accordance with Technical Specification 3.2.F.

Furthermore, fuel damage does not occur due to an uncontrolled rod withdrawal from cold shutdown. Therefore, removing the requirement for containment integrity with less than a 5% shutdown margin and the reactor

-**head unbolted and for planned positive reactivity additions due to rod motion or boron dilution also will not increase the consequences of any previously analyzed accident.

• Implementing various administrative changes, which include removing the containment isolation valve tables, eliminating the redundant requirements on Figure 3.8-1, capitalizing the defined words and changing the acronyms from FSAR to UFSAR does not impact plant design or operation. The administrative changes will not increase the probability of occurrence or consequences of any accident previously evaluated.

2. Create the possibility of a new or different type of accident from any accident previously evaluated. The plant's design and operation are not being changed.

Providing Action Statements for breaches of containment integrity, modifying the definition of containment integrity, eliminating the requirement for containment integrity in cold shutdown and refueling shutdown, clarifying the containment isolation requirements for refueling operations, clarifying the containment air partial pressure requirements, and implementing various administrative changes do not generate any new accident precursors. Thus, no new or different kind of accident is being created.

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3. Involve a significant reduction in a margin of safety. Physical plant modifications, or changes in plant operation are not being made. The Technical Specification requirements for containmenf integrity/isolation are being clarified and appropriate Action Statements and allowed outage times are being*

established for operation with a breach of containment integrity. -Although the requirements for containment integrity 1) when the reactor head is unbolted and the shutdown margin less than 5%~k/k and 2) during positive reactivity additions are being removed, both analyzed accident scenarios (i.e.,

uncontrolled rod withdrawal from subcritical conditions and inadvertent boron dilution) can be precluded or terminated by automatic or manual operator actions prior to any challenge to fuel cladding integrity. The accident analyses do not assume containment integrity to be established for the accidents analyzed in the cold shutdown and refueling shutdown conditions. These administrative changes have no impact on plant operation or the accident analysis assumptions and results. The existing assumptions used in the accident analysis are not being altered. Therefore, the margin of safety will not be reduced by any of the proposed changes.

Using the examples identified in the Federal Register, Volume 51, No.44, of March 6, 1986 that are not considered likely to involve significant hazard considerations, the proposed changes are similar to examples (i), (ii), and (vii).

• Example (i) is "a purely administrative change to technical specifications: for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature." The proposed capitalizing defined words and changing the acronym from FSAR to UFSAR in the references is purely administrative.

• Example (ii) is "a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, e.g., a more stringent surveillance requirement." The proposed change formally incorporates Limiting Conditions for Operation and Action Statements for both

1) breaches of containment integrity and 2) operation with containment air partial pressure outside the allowable limits.

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• Example (vii) is "a change to conform a license to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations." Removal of the* containment isolation valve tables from the Technical Specifications is consistent with the guidance provided in Generic Letter 91-08, "Removal of Component Lists From Technical Specifications."