ML20058D586
| ML20058D586 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/23/1993 |
| From: | WISCONSIN ELECTRIC POWER CO. |
| To: | |
| Shared Package | |
| ML20058D581 | List: |
| References | |
| NUDOCS 9312030217 | |
| Download: ML20058D586 (12) | |
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-m w-k TECHNICAL SPECIFICATION CHANGE REQUEST 163
. l SAFETY EVALUATION INTRODUCTION-
- i Wisconsin Electric Power Company (Licensee)::is' applying for.
amendments to Facility Operating License DPR-24.and DPR-27Efor-
' Point Beach Nuclear: Plant, Units 1-and.2.
The' requested amendments-propose several changes to Section'15.3.6;
" Containment System," to enhance the. operating conditions and limiting conditions for operation for containment 1 systems.. This wk change also proposes revisions to Sections 15.1s " Definitions,"
and 15.4.4, " Containment Tests," to support;the. changes to a
Section 15.3.6.
_ Additionally,. revisions lare proposed to the d
basec for Section 15.3.6 to support these changes.,
EVALUATION i
This Technical Specificati.on Change Request is.being submitted 1
. because:we believe the curre.7t limiting conditionsLfor operation-j l(LCO's) regarding containment operability should be more specific c
regarding requirements for operability and actions to be taken if the require.ents are not met.
As stated in Technical Specifications. (TS) Section 15.1,
" Definitions," containment integrity is defined to exist when:
All non-automatic containment' isolation ~ valves and. blind
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- 1) '
flanges:are closed as required.
1 2)
The equipment hatch is properly' closed.
3)
At least-one door in each personnel air lock is properly closed.
4)
All automatic containment. isolation valves lare operable l.or-are secured closed.
5)
The uncontrolled containment leakage satisfies: Specification:
15.4.4, " Containment Tests."-
Items 1 and 4 refer to the operability of individuab containment isolation valves rather_than the' penetration to which they_
belong.
As'the_ changes to Section'15.3.6.A, " Containment-35 Integrity,"'are' based on the operability of containment ~
penetrations, a revision to this definition-is proposed that-statesLthel requirements for operability _of penetrations and eliminates items ~1 and.4.
Item 5 refers lto the limit on containment leakage.
A revision to
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n this-item is proposed to more clearly state the leakage limitcfor containment operability.
See the discussion of proposed
- Specification 15.3.6.A.1.a, below.
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..i 9312030217 9311231 3
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The proposed changes to Section 15.3.6.A address each of_these requirements for containment integrity individually.
Appropriate time intervals are included for each LCO to eliminate the need to default to the generic time' limits of Section'15.3.0, " General-Considerations."
Section 15.3.0 states that if an LCO does not prescribe a time period, the affected unit shall be placed in hot shutdown within three hours of discovering the situation.
If the conditions which prompted the shutdown cannot be corrected, the unit shall lx3 placed in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovering the situation.
Currently, Specification 15.3.6.A.a) states that containment integrity must not be violated when a nuclear core is installed' in the reactor unless the reactor is in the cold shutdown condition.
Specification 15.3.6.A.b) states that containment integrity must not be violated when the reactor vessel head is removed unless the reactor is in the refueling shutdown condition.
Specifications 15.3.6.A.a) and b) have been_ combined into.one item, proposed Specification 15.3.6.A.1, and the wording changed slightly to cover all cases where containment integrity must be maintained.
In the event containment integrity is not maintained when required, a sentence has been added to direct the operator to the applicable LCO(s) for the reason containment integrity was not maintaincd.
If an LCO is met or-is no longer applicable prior to the expiration of the specified completion time (s), a sentence has been added to tell the operator that completion.of the required action (s) is not required unless otherwise stated.
Proposed Specification 15.3.6.A.1.a addresses containment operability and covers the proposed revision to requirement 5) of the definition of containment integrity in Section 15'1.
As stated in the proposed revisions to the bases, the containment is considered operable if overall containment leakage is within the acceptance criteria of 10 CFR 50, Appendix _J,
" Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors."
If overall containment leakage exceeds the acceptance criteria of Appendix J, the condition must be corrected within one hour.
This provides a period of time to correct the problem commen--
surate with the importance of maintaining containmentfintegrity when the plant is in a condition other than cold or-refueling shutdown.
This time period also ensures that the probability of an accident (requiring containment integrity) occurring during periods when containment is inoperable is minimal.
If containment leakage cannot be restored to within limits within
'the required completion time, the plant must be placed in a d.
condition to which the LCO does not apply.
To achieve this status, the plant must be brought to at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
These times 2
are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner without challenging plant systems.
Proposed Specification 15.3.6.A.I.b addresses containment isolation valves and covers requirements 1) and 4) of the existing definition of containment integrity in Section.15.1.
The specification allows penetration flow paths, except for purge supply and exhaust valve penetration flow paths, to be un-isolated intermittently under administrative controls.
These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication.with the control room.
In this way, the penetration can be rapidly isolated if a need for containment isolation is identified.
Cases where a dedicated operator may be used to un-isolate a penetration intermittently include testing to demonstrate restored operability, maintenance on the system, and on systems that are required to be used intermittently.
Due to the size of the containment purge line per.etration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls.
Current Specification =15.3.6.C (which will be renumbered to 15.3.6.A.1.c) addresses purge supply and exhaust valves.
A statement is included to clarify that, for this LCO, separate condition entry is allowed for each penetration flow path.
A statement is included to ensure appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.
In the event that containment penetration leakage results in exceeding the overall containment leakage rate, a statement directs entry into proposed Specification 15.3.6.A.1.a, in addition to the applicable LCO of-15.3.6.A.1.b.
Proposed Specification 15.3.6.A.1.b is divided into two parts; one for penetration flow paths with two containment isolation valves, and one for penetration flow paths with one containment isolation valve and a closed system.
If one containment isolation valve is inoperable in a penetration flow path with two containment isolation valves,'the affected penetration flow path must be isolated.
The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.
Isolation barriers that meet this criterion are a closed and deactivated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through 3
~ the valve secured.
The valve used.to isolate-the penetration should be the closest available one.to containment.
This action must be completed.within four hours.
The'four hour completion time is: reasonable, considering the time required to' isolate.tha
. penetration and.the_ relative importance of, supporting containmenti operability _when the plant is in a condition other_than' cold-or refueling shutdown.
Penetration flow paths that cannot be restored to operable status' within the four hour completion time and have been isolated lin-accordance with TS 15. 3.6. A.1.b. (1) (a) (i), must be - verified isolated.on a periodic basis.
This ensures containment penetrations which are_ required to be isolatedLfollowing an' i
y accident, but are no longer capable of being automatically 1
isolated, will be in the isolation position should~an accident..
occur.. This action does not require any-testing or. valve' manipulation.
Rather, it involves verification, throughLa' system walkdown, that those isolation devices outside containment'and' capable of being mispositioned are in the correct ~ position.- The time interval of "once per 31 days for isolation devices outside.
containment" is appropriate considering the valves are operated under administrative controls and the probability.of'their.
misalignment is low.
For' isolation devices inside containment, the time period specified as " prior to exceeding 200*F, if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the
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r inaccessibility of the isolation devices _and other administrative 1 controls that will ensure that isolation device misalignment is an unlikely possibility.
.I A sentence is included that allows valves and blind flanges located in high radiation areas to be verified closed by use of' l
administrative means.
Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. 'Therefore, the probabilitytofLmisalignment1 of these valves, once they have been verified to be in'the. proper position,-is small.
This method'is also consistent with
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maintaining personnel exposure as low as reasonably achievable; j
If.two containment isolation valves are inoperable'in a.
penetration flow path with two. containment isolation valves, the_
affected penetration flow path must be isolated within_one hour.-
.1 The method of isolation must include the use of atileast-one j
isolation. barrier that cannot be adversely affected'by'a single active. failure.
Isolation barriers that meet this criterion are a closed and deactivated automatic valve, a closed manual valve,-
and a blind flange.
i The one hour completion time'is consistent with proposed Specification 15.3.6.A.1.a.
Penetrations isolated in accordance l
with proposed Specification 15.3.6. A.1.b. (1) (b) (1), must be verified isolated on a periodic basis.
This assures-the leak 4
I L)
A
t tightness of containment and that penetrations requiring isolation following an accident are isolated.
The basis for the completion times is similar to that for proposed Specification
+
- 15. 3. 6. A.1.b. (1) (a) (i) mentioned above.
A sentence is included that allows valves and blind flanges l
located in high radiation areas to be verified closed by use of:
L administrative means.
The basis for this is similar to that for proposed Specification 15.3.6. A.1.b. (1) (a) (i) mentioned above.-
If one containment isolation valve is inoperable in a penetration flow path with one containment isolation valve and a closed L
system, the affected penetration flow path-must be isolated L
within four hours.
The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.
Isolation barriers that p
meet this criterion are a closed and deactivated automatic valve, a closed manual valve, and a blind flange.
A check valve may not be used to isolate the affected penetration flow path.
The four hour completion time is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of maintaining containment integrity when the plant is in a condition other than cold or refueling shutdown.
Penetration flow paths isolated in accordance with. proposed Specification 15. 3. 6. A.1.b. (2) (a) (i) must be verified isolated on a periodic basis.
This periodic verification assures the-leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated.
The completion time of once per 31 days is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low.
A sentence is included that allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means.
The basis for this is similar to that for proposed Specification 15. 3. 6. A.1.b. (1) (a) (i) mentioned above.
-l If the required actions and associated completion times are not met, the plant must be placed in a condition to which the LCO does not apply.
To achieve this status, the plant must be -
brought to at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
These times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner without challenging plant systems.
l Existing Specification 15.3.6.C, " Containment Purge Supply and Exhaust valves," has been renumbered to Specification 15.3.6.A.1.c.
The reference to TS 15.4.4.II.B.1.b has been deleted as that section is being deleted as part of this change.
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A sentence has been added to direct entry into proposed Specification 15.3.6.A.1.a if purge supply and exhaust penetration leakage results in exceeding the overall containment leakage rate limit.
Proposed Specification 15.3.6.A.1.d addresses containment air locks and covers requirements 2) and 3) of the existing definition of containment integrity in Section 15.1.
l Containment entry and exit is allowed to perform repairs on the affected air lock component.
If the outer door is inoperable, it may be easily accessed for repairs.
If the inner door is the one that is inoperable, however, a short time exists when the containment boundary is not intact (during access.through the outer door).
The ability to open the operable door, even if it means the containment boundary is temporarily not intact,-is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the operable door is-expected to be open.
After each entry and exit, the operable door must be immediately closed.
If ALARA conditions permit, entry and exit should be via an operable air lock.
A statement is included to clarify that, for this LCO, separate condition entry is allowed for each air lock, t
In the event that air lock leakage results in exceeding the overall containment leakage rate limit, a statement directs entry into proposed Specification 15.3.6.A.1.a for containment operability.
If one air lock door in one or both containment air locks is inoperable, the operable door must be verified closed in each affected containment air lock.
This ensures a leak tight containment barrier is maintained by the use of an operable air i
lock door.
This action must be completed within one hour.
This.
specified time period is consistent with proposed Specification 15.3.6.A.1.a for containment operability.
l The affected air lock penetration must be isolated by locking
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closed the operable air lock door within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This completion time is reasonable considering the operable door of the affected air lock is being maintained closed.
j Proposed specification 15.3.6. A.1.d (1) (c) verifies that an air I
lock with an inoperable door has been isolated by the use of a locked and closed operable air lock door.- This ensures an acceptable containment Icakage boundary is maintained.
The completion time of once per 31 days is based on engineering 1
~ judgment and is considered adequate in view of the. low likelihood of a locked door being mispositioned and other administrative l
controls.
i 6
j A sentence is included-that allows air lock doors located in high radiation areas to be verified locked closed by use of
-administrative means.
This is considered acceptable, since access to these areas is typically restricted.
Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.
The actions of TS 15.3.6.A.1.d.(1) are not applicable if both doors in the same air lock are inoperable and proposed Specification 15.3.6.A.1.d.(3) is entered.
With both doors in the same air lock inoperable, an-operable door is not available to be closed.
Proposed Specification 15.3.6.A.1.d.(3) contains the appropriate remedial actions for this condition.
A sentence is included that allows use of the air lock for containment entry and exit for 7 days under administrative controls if both air locks are inoperable.
Containment entry.may.
.t be required on a periodic basis to perform TS surveillances and required actions, as well as other activities on equipment inside containment that are required by TS or activities on equipment that support TS required equipment.
This does not preclude-performing other activities (i.e., non-TS required activities) if the containment is entered, using the inoperable air lock, to perform an allowed activity listed above.
This allowance is.
acceptable due to the low probability of an event that could pressurize the containment during the short time that the operable door is expected to be open.
Proposed Specification 15.3.6.A.1.d.(2) addresses inoperable air lock door interlock mechanisms.
For an inoperable air lock interlock mechanism in one or both air locks, the required actions and associated completion times are consistent with those of proposed Specification 15.3. 6. A.1.d. (1) mentioned above. -
The actions of TS 15.3.6.A.1.d.(2) are not applicable if both doors in the same air lock are inoperable and proposed Specification 15.3.6.A.1.d.(3) is entered.
With both doors in the same air lock inoperable, an operable door is not available i
to be closed.
Proposed Specification 15.3.6.A.1.d.(3) contains the appropriate remedial actions for this condition..
Entry into and exit from containment is allowed under the control of a dedicated individual stationed at the air lock to ensure ~that only one door is opened at a time (i.e., the individual performs the function of the interlock).
A sentence is included that allows air lock doors located in high radiation areas to be verified locked closed by use of administrative means.
This is considered acceptable, since access to these areas is typically restricted.
Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.
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With one or both air locks inoperable for reasons other than those described in TS 15.3. 6. A.1.d. (1) or (2), proposed Specification 15.3.6.A.1.d.(3) requires action to be initiated immediately to evaluate previous combined leakage rates using current air lock test results.
An evaluation is acceptable, since it is overly conservative'to immediately declare the containment' inoperable if both doors'in an air lock have failed a seal test or if the overall air lock leakage is not within f
limits.
In many instances (e.g.,
only one seal per door has failed), containment remains operable, yet only one hour (per proposed Specification 15.3.6.A.1.a) would be.provided to restore the air lock door to operable status prior to' requiring a plant' shutdown.
In addition, even with both doors failing'the. seal test, the overall containment leakage rate can still be within limits.
Proposed Specification 15. 3. 6. A.1.d. (3) (b) requires that one door in the affected containment air lock be verified closed within one hour.
This specified time period is consistent with TS 15.3.6.A.1.a, which requires overall containment leakage be restored to within limits within one hour.
'I Additionally, the affected air lock (s) must be restored to operable status within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
This time period is considered reasonable for restoring an inoperable air lock to operable i
status, including a post-maintenance pressure test, assuming that at least one door is maintained closed in each affected air lock.
If the inoperable containment air lock cannot be restored to operable status within the required completion time, the plant must be placed in a condition to which the LCO does not apply.
To achieve this status, the plant must be brought to at least hot 1
shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
{
These times are reasonable, based on operating experience, to i
reach the required plant conditions from full power conditions in an orderly manner without challenging plant systems.
)
Existing Specifications 15.3.6.A.c) and d) have been renumbered to 15.3.6.C and D.
This change is administrative.
The wording of these specifications has not changed.
A change is proposed to Specification 15.3.6.B, " Internal Pressure," to provide a specific completion time for correcting problems with containment internal pressure.
In its present form, this specification states that if pressure is not within the limits of the LCO, the condition shall be corrected or the reactor rendered subcritical.
As no time limit is given, Section 15.3.0 applies, requiring the reactor be placed in hot shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovery of the condition.
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l The proposed change states that.the condition shall be corrected' within one hour.
The required action is necessary to return operation to within the bounds of the containment analysis.
This
.specified time period is consistent with proposed Specification-15.3.6.A.1.a for containment operability.
If containment pressure cannot be restored to within. limits within one hour, the plant must be placed in a condition to.which the LCO does not apply.
To achieve this status, the plant must E
be brought to at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
These times are reasonable, based.on operating experience, to reach the required plant conditions'from full power conditions in an orderly manner without cnallenging plant systems.
A change is proposed to Section 15.4.4, " Containment Tests,"
Specification II.B.1, which gives the acceptance criterion for Type B containment leakage tests.
This specification currently requires that repairs be initiated immediately and a retest performed if the total of Type B and C leakage tests exceeds 0. 6 L,.
It also requires the plant be taken to cold shutdown if the repairs are not completed and conformance to the acceptance criterion is not demonstrated within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
This is essentially an LCO and does not belong in Section 15.4,
" Surveillance Requirements."
Furthermore, it is inconsistent with the intent of the proposed changes to Section 15.3.6 in that repairs do not need to be performed immediately if the penetration can be isolated.
The proposed change directs the operator to enter the appropriate LC0(s) of Section 15.3.6 when the total of Type B and C leakage exceeds 0.6L,.
A similar change is proposed to Specification III.C of Section 15.4.4, which contains the acceptance criterion for Type C containment leakage tests.
CONCLUSIONS In summary, all of the proposed changes to the Technical Specifications are being made.to make the LCOs for containment systems more specific'with regard to requirements.for operability and actions to be taken if the requirements are not met.
No existing requirements are being removed and several.are being added.
Time intervals for some existing requirements are being changed.
The time intervals are consistent with Westinghouse Improved Standard Technical Specifications, NUREG 1431, or with current Point Beach Nuclear Plant practices.
The proposed changes will ensure and enhance the continued saf'e operation of the Point Beach Nuclear Plant.
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i TECHNICAL SPECIFICATION CHANGE REOUEST 163-NO SIGNIFICANT HAZARDS DETERMINATION As required.by 10 CFR 50.91(a), we have evaluated the proposed changes and have determined that they do not involve la signifi-
-cant hazards consideration.
Our analysis against'each=of the criteria in 10 CFR 50.92 follows.
1.
The proposed amendments will not involve a significant-increase in the probability or consequences of an accident previously evaluated.
6 The proposed changes will add operating conditions and limiting conditions for operation to-Section 15.3.6,
" Containment System," of the Point Beach Nuclear Plant (PBNP) Technical Specifications (TS)..This change also proposes revisions to Sections 15.1, " Definitions," and 15.4.4, " Containment Tests," to support the' changes to Section 15.3.6.
Additionally, the change.will add explanatory text to the bases for Section'15.3.6 to-support the revisions.
The proposed revisions will add more specific' limiting conditions for operation (LCOs) for containment isolation valves, air locks, overall containment air leakage, and internal pressure.
The proposed LCOs state.more clearly the requirements for operability and the actions to be taken if
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the requirements are not met.
.The proposed LCOs~ reflect the intent of the Westinghouse Improved Standard Technical Specifications, NUREG-1431.
None of the existing-LCOs are being removed.
As most of the existing LCOs in Section 15.3.6 do not specify completion times for required actions, Section 15.3.0, " General Considerations," applies.-.Section 15.3.0 states that if an LCO does not prescribe a' time period,Lthe affected unit shall be placed in hot shutdown within three hours of discovering.the situation.
If the conditions which prompted the shutdown cannot be corrected, the' unit shall be placed in cold shutdown within 48' hours of' discovering;the situation.
The proposed revisions to Section 15.3.6'specify appropriate completion times for each LCO to eliminate.the.
need to default to.the generic time requirements given.in Section 15.3.0.
If the required actions and associated completion times are not met, the plant must'be brought to at least hot shutdown within.6-hours and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.- The slightly. longer time.to hot; shutdown-is more-than of fset by the shorter time to-cold shutdown,-
thereby reducing the consequences of a release from-containment.
These times-are reasonable, based on operating 1
=
experience, to reach the required plant conditions from full
. power conditions in an orderly manner without challenging plant systems.
There is no physical change to the facility, its systems, or its operation.
Therefore, there is no increase in the probability.or consequences of an accident previously l
evaluated.
2.
The proposed amendments will not create the possibility of a new or different kind of accident from any accident previously analyzed.
The proposed changes will add operating conditions and limiting conditions for operation to Section 15.3.6',
" Containment System," of-the Point Beach Nuclear Plant (PBNP) Technical Specifications (TS).
This change also.
proposes revisions to Sections 15.1,-" Definitions," and 15.4.4, " Containment Tests," to support the changes to Section 15.3.6.
Additionally, the change will add explanatory text to the bases for Section 15.3.6 to support the revisions.
The proposed revisions will add more specific LCOs for.
containment isolation valves, air locks, overall. containment i
air leakage, and internal pressure.
The proposed LCOs state more clearly the requirements for operability'and the actions to be taken if the requirements are not met.
The proposed LCOs reflect the intent of the Westinghouse Improved Standard Technical Specifications, NUREG-1431.
None of the existing LCOs are being removed.
As most of the existing LCOs in Section 15.3.6 do not specify completion times for required actions, Section 15.3.0, " General Considerations," applies.
Section:15.3.0 states that if an LCO does not prescribe a time period, the affected unit shall be placed in hot shutdown within'three.
hours of discovering the situation.
If the conditions which prompted the shutdown cannot be corrected, the unit shall be placed in cold shutdown within 48-hours of. discovering the situation.
The proposed revisions to Section 15.3.6 specify appropriate completion times for each LCO to eliminate the need to default to the generic time requirements given in Section 15.3.0.
If-the required actions'and associated completion times are not met, the plant.must be brought-to at least hot shutdown within-6 hours and to cold shutdown within 36. hours.
The slightly longer time to hot shutdown-is more than offset by the shorter time to cold shutdown, thereby reducing the consequences of a release from
]
i containment.
These times are reasonable,. based on operating 2
experience, to reach the required plant conditions from full' power conditions in an orderly manner without challenging plant systems.
There is no physical change to the facility, its systems, or its operation.
Thus, a new or different kind of accident cannot occur.
3.
The proposed amendments will not involve a significant reduction in the margin of safety.
The proposed changes will add operating conditions and limiting conditions for operation to Section 15.3.6,
" Containment System," of the Point Beach Nuclear Plant (PBNP) Technical Specifications (TS).
This change also proposes revisions to Sections 15.1, " Definitions," and 15.4.4, " Containment Tests," to support the changes to Section 15.3.6.
Additionally, the change will add explanatory text to the bases for Section 15.3.6 to support the revisions.
The proposed revisions will add more specific LCOs for containment isolation valves, air locks, overall containment air leakage, and internal pressure.
The proposed LCOs state more clearly the requirements for operability and the actions to be taken if the requirements are not met.
The.
proposed LCOs reflect the intent of the Westinghouse Improved Standard Technical Specifications, NUREG-1431.
None of the existing LCOs are being removed.
As most of the existing LCOs in.Section 15.3.6 do not specify completion times for required actions, Section 15.3.0, " General Considerations," applies.
Section'15.3.0 states that if an LCO does not prescribe a. time period, the affected unit shall be placed in hot shutdown within three hours of discovering the situation.
If the conditions.which prompted the shutdown cannot be corrected, the' unit'shall be placed in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovering ~the-situation.
The proposed revisions to Section 15.3.6 specify appropriate completion times for each ICO to eliminate-the-need to default to the generic time re.auirements given-in Section 15.3.0.
If the required actions and' associated' completion times are not met, the plant must be' brought to' at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The slightly longer time to' hot shutdown-is more than offset by the shorter. time to. cold shutdown,.
L thereby reducing the consequences of a release-from containment.
These times are reasonable, based on-operating.
'i experience, to reach the required plant conditions from. full power conditions in an orderly manner without challenging plant systems.
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I There is no physical change to the facility, its systems, _or its operation.
Thus, a significant reduction in a margin of safety cannot occur.
In fact, by adding more. specific LCOs for containment integrity and allowing for a more orderly unit shutdown when required, an increased margin of safety may.be realized.
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