Text

Proposed Tech Specs 3.6.1.1, Containment Integrity & 3.6.1.3, Containment Air Locks
	ML20063G295
Person / Time
Site:	Beaver Valley
Issue date:	02/04/1994
From:	; DUQUESNE LIGHT CO.
To:	;
Shared Package
ML20063G291	List: ML20063G282; ML20063G295;
References
	NUDOCS 9402150410
	Download: ML20063G295 (100)
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{{#Wiki_filter:. _ . ._ -. .- - -. .. i ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1

Proposed Technical Specification Change No. 199, Revision 1 '

i The following is a list of the affected pages: l

                                                                                                            ,l Affected Pages:        XIV 1-2                                                                I 3/4 6-1                                                          '

l 3/4 6-5 3/4 6-Sa f B 3/4 6-1 l s b i i 9 4 f

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i l i I I l

9402150410 940204 ! PDR ADDCK 05000334 P PDR _ _ _ - _ - _ _ - _ - - - - _ - _ _ - _ _ _ _ _ _ _l

DPR-66' - INDEX l BASES SECTION PAGE i 3/4.6 CONTAINMENT SYSTEMS _ 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 Containment Integrity . . . . . . . . . . B 3/4 6-1 , l 3/4.6.1.2 Containment Leakage . . . . . . . . . . . B 3/4 6-1 , 3/4.6.1.3 Containment Airlocks . . . . . . . . . . B 3/4 6-1 - 3/4.6.1.4 & 3/4.6.1.5 Internal Pressure and Air Temperature . . B 3/4 6 'S 3/4.6.1.6 Containment Structural Integrity . . . . B 3/4 6-2 i 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 & Containment Quench and Recirculation 3/4.6.2.2

Spray Systems . . . . . . . . . . . . . . B 3/4 6 dg.

3/4.6.2.3 Chemical Addition System . . . . . . . . B 3/4 6-3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . B 3/4 6-X 3/4.6.4 COMBUSTIBLE GAS CONTROL . . . . . . . . . B 3/4 6-% - r 3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM II 3/4.6.5.1 Steam Jet Air Ejector . . . . . . . . . . B 3/4 6-1 i 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE 3/4.7.1.1 Safety Valves . . . . . . . . . . . . . . B 3/4 7-1 3/4.7.1.2 Auxiliary Feedwater Pumps . . . . . . . . B 3/4 7-2 3/4.7.1.3 Primary Plant Demineralized Water . . . . B 3/4 7-2 3/4.7.1.4 Activity . . . . . . . . . . . . . . . . B 3/4 7-3 3/4.7.1.5 Main Steam Line Isolation Valves . . . . B 3/4 7-3 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION . . . . . . . . . . . . . . . B 3/4 7-4 BEAVER VALLEY - UNIT 1 XIV Amendment No. (frofosch W eA m , P

DPR-66 DEFINITIONS REPORTABLE EVENT 1.7 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50. CONTAINMENT' INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when: 1.8.1 All penetrations required to be closed during accident conditions are either:

a. Capable of being closed by an OPERABLE containment automatic isolation valve system, or

b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except as provided in Table 3.6-1 of Specification 3.6.3.1.

1.8.2 All equipment hatches are closed and sealed qg) 1.8.3 Each air lock is OPERABLE-pur-suant-te Specification 3.6.1.3, 4% , y ,p] 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2 6 A00 % s.5 % subg mec63 ntsouob) w A e.& p.wh6 (eg. ,wdas, b bw3, CHANNEL CALIBRATION k of o-f g)S) is ov'ER AdLE , 1.9 A CHANNEL CALIBRATION shall be the adjuctment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated. CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter. BEAVER VALLEY - UNIT 1 1-2 Amendment No. [9refosch Werbs

                                                                                     +.  ;

DPR-66 3/4.6 CONTAINMENT SYSTEMS [ 3 /4. 6.1 PRIMARY CONTAINMEITT CCNTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained. APPLICABILITY: MODES 1, 2, 3 and 4. j ACTION: Without primary CONTAINMENT INTEGRITY, restore. CONTAINMENT INTEGRITY : within one hour or be in at least HOT STANDBY within the next 6' hours and in COLD SHUTDOWN within the following 36 hours. SURVEILLANCE REQUIREMENTS ; 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per :;l days by verifying that: _

g-{D '

1. All penetrationsX not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-1 of Specification 3.6.3.1. 'l

2. All equipment hatches are closed and sealed. ;

b. By verifying that each containment air lock is OPERAELE per4 ,

Specification 3.6.1.3. g g

                                                               ,                           i hTtWT "Ab Q)--pK      Except    valves,   blind flanges, and deactivated automatic valves which    are located inside the containment and are locked, sealed,           '

or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that i such verification need not be performed more often than once per l 92 days. ! l l BEAVER VALLEY - UNIT 1 3/4 6-1 Amendment No. 1 f6 O ^

s. Attachment to " Containment Intearity" I [ INSERT "A"

c. After each closing of each penetration subject to Type B testing, except the containment air locks, if opened following a Type A or 9 test, by leak rate testing the sealc with gas at a pressure not less than-Pa (40.0 psig), and verifying that when the measured leakage rate for these t seals- is added to the leakage rates determined pursuant to ;

Specification 4.6.1.2.d for all other- Type B and C penetrations, the combined leakage rate is less than 0.60 L a* F l > 1 BEAVER VALLEY - UNIT 1 (Proposed Wording) i

     - -                         s

DPR-66 t CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS , i LIMITING CONDITION FOR OPERATION 6.1.3 1 containment air Joc shall be OPERABLE

a. Beth--deer; cicacd cxcept when the sir lack is being used ORETE-3 ror-norear--transit-entry--and-enet thrcugh the containment, i then at-least=one-air lock door-sho41 he cleced and 1

An cverall air lack leakage rato af less than er equal te (b. <h05L a Ot P a I'0 0 PC19 )* APPLICABILITY: MODES 1, 2, 3 and 4. _ m one er VWete ACTION: a y snhmme.skaelotdih 400 TNJERT B

a. With one containment air lock door inoperableV I

N fholp ofEfMlE 1. Maint ir the acerosieted OrrIAELE si; ; ; .ch d . A. eleccd ' he y cid A and either rootorc--th; &;s ~ivi.ed i..%.m'.,1 c.n lvuk l 4g ,, g I deer tc OPERABLE--status within 24 hours er ck the :

N ey**) accOc[i2*0dOPERABLEa4-rlcckdoorclosedwg apt th4 .,4.cq ,o,%w gg u,3

s. Operatien na/ thc. continuc--until pcrfcreance-cf the gg nc::t "cquirc' N einil air icck leeks,ge test prcvided l f

that thc associetMPERADLE - cir lock decr is verifim ! deer is " te-be, locked closed mhe at l_q6ebl eastair once per 31 days. g l le etO j

                            '5     Otherwise, be in at least HOT STANDBY within the next                                           l OE M                  M6            hours and in COLD SHUTDOWN within the following 30
                             \

h, hours. hfLME WIT The provicion; cf specificatign 3.0.4 crc not

~ D OS E R,T " C                   applicable.

b. With a containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status within 24 hours or be in at least HOT STANDBY withinthenext6hoursandinCOLDSHUTDOWNwithinj the following 30 hours.

A00

                    \              . . - - - -

(HT Ewb ed ud 'is f erds55Mt 4*r h3 "A *' " A*"O "*\ '# ' y pecken aek.a.%s nu rzh%h A % retse o4 *L hh "\*'A'*'t'*N'

6) At letX doses tw k e c,$ ,,k s w occuj vw.) bs Ottikeb loodtb C\63eb

                               % ahw,a sik rahvc M= *S, (6')    ray . J ea A corbia is n unMe          n      "d* c'4'd 'k a dd'"A*S #4"'M                      J BEAVER VALLEY - UNIT 1                               3/4 6-5                    Amendment No.

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             -.     -                     -.          ~.                    -       -      . _ .     .-

i i Attachment to " Containment Air Locks" l l INSERT "B" .l

                                       - - GENERAL NOTES - - - - - - - - - - - - - -'                   .l

1. Entry and ' exit is permissible.-to perform repairs on the' l affected air lock components. .j

2. Separate ACTION statement entry is allowed for each air l lock. '

3. Enter the ACTION of LCO 3.6.1.1, when air lock leakage ,

results in exceeding the combined containment leakage rate. ! INSERT "C"

b. With the containment air lock interloc i inoperable in one or more containment air locks: 6) mechanism q

1. Verify an OPERABLE door is closed in the affected air l lock within 1 hour, and -1

2. Lock an OPERABLE door closed in the affected air lock l within 24 hours, and

3. Verify an OPERABLE door is locked clos g in the ;

affected air lock at least once per 31 days. ,

4. Otherwise, be in at least HOT STANDBY within the next ,

f 6 hours and in COLD SHUTDOWN within the following 30 hours. ;

c. With one or more containment air locks inoperable, except i as the result of. an inoperable air lock door and/or i inoperable interlock mechanism: j 1

1. Immediately initiate action -to evaluate the combined :

containment leakage rate'per LCO 3.6.1.2, and ]

2. Verify a door is closed in the affected air lock, !

within I hour, and . 1

3. Restore the air lock to OPERABLE status within 24 hours.

4. Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. l l

BEAVER VALLEY - UNIT 1 (Proposed Wording)

DPR-66 CONTAINMENT SYSTEMS l SURVEILLANCE REQUIREMENTS 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:

a. Within 72 hours following each containment entry, except when the air lock is being used for multiple entries, then at least once per 72 hours,"by verifying .

no detectable seal leakage when the gap between the 1 door seals is pressurized for at least 2 minutes to: ' 1. Personnel airlock Q .0 psig (@ '"h' * * * '@ +'} j

2. Emergency air loc.k [10.0 psig 4EFLACE wsTR -

g3pg <<D n for by quantifying the total air lock

                       % s,ure the requirements of 3.6.1.3.b are met. leakage                       to          i
                                                                                                                }

b. By conducting overall airlockleakagetests,Wtnot less than P a (40.0 psig), and verifying the overall ;

air lock leakage rate is "ithin " it; limit:/tess N or u.H e l

1. Qar t.. a 9 o.o g) I At least once per 6 months, [ and g

2. pen eccplcticn cf maintenance "hich has been friv46 esObsh ?f performed on the air loc that could affect the caNTAiNtW.HT It41YGHITY Johew air lock sealing capabili g

c. At least once per 18 months during shutdown by verifying:

1. Only one door in each air lock can be opened at a l timee hDELE TE (z. ::c dctcctchlc ccc1 Icckcg: whcn thc volurd !

bctVccn the c;crgency 01: lock chaft cccic '- { preccuri;;cd to greater than er eq"cl tc 10 0 prig Icr ct 1ccct 2 minutcc. l _s 1' DELETE

                                                            .. ,. 4. ~ o ,    m . u , e.,,  - a -.c  ,

f 7.n.sM t ocd. m. m p.c 4 .I hte @ k

7a.ru at m Q on v se.k3rc deT.e se. m chruft Arce J c, ,

NT The provisions of Specification 4.0.2 are not applicable. so 'X Exemption to Appendix J of 10 CFR 50, dated November 19, 1984. hyg two cr=M t. mr \otN doge does Q twndidde h prediewf su ccess \ periors.nce, oS %. oute.\\ as MW tc..d.g hst, t des.\h .5k\\ ha eva\M ap- 4bt GCtcPMt Cr'\'r'* 'I E4D 3 &'I'O ' ! C(O ' ADO I 1 BEAVER VALLEY - UNIT 1 3/4 6-5a Amendment No. { (froposchWothin

t Attachment to " Containment Air Locks" )

     -INSERT "D" l

l or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less than or equal to 0.0005 La at P (40.0 psig) for the personnel air lock and 0.0005 La at. l 18.0 psig for the emergency air lock. l l l l_ ! 1 l l l l l i l i 3 2 BEAVER VALLEY - UNIT 1 (Proposed Wording) I t

h DPR-66 3/4.6 CONTAINMENT SYSTEMS , BASES , r 3/4.6.1 PRIMARY CONTAINMENT i 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of , radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with the leakage rate limitation, will limit the site boundary radiation - doses to within the limits of 10 CFR 100 during accident conditions. j 3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure, Pa. As an added conservatism, the measured overall integrated leakage rate is further limited to $ 0.75 La during performance of the periodic test - to account for possible degradation of the containment leakage barriers between leakage tests. The surveillance testing for measuring leakage rates are consistent with the requirements of Appendix "J" of 10 CFR 50. The exemption to 10 CFR 50 Appendix J.III.D.1(a) allows Type A tests y to be conducted on a 40 10-month schedule, not in conjunction with any ISI tests. ; 3/4.6.1.3 CONTAINMENT AIR LOCKS r hhe locks limitations on closure and leakrateforthecontainmentairh are required to meet the restrictions on CONTAINMENT INTEGRITY ' . and containment leak rate. Surveillance testing of the air lock seals provides assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between air ck leakage tests. _ j REPL ACE unTR INSEfi- " E. "

n BEAVER VALLEY - UNIT 1 B 3/4 6-1 Amendment No. {ft%foScb Uorb

    .- . . -       . -        - _ .   -.        -        - ~.  . _ . -    -. - -. .-           . . . _ .

i Attachment to " Containment Air Locks" j INSERT "E" ! i BACKGROUND j i Containment air locks form part of the containment pressure boundary l and provide a means for personnel access during all MODES of f operation. ; i Each air lock is nominally a right circular cylinder, with a door at ! each end. The doors are interlocked to prevent simultaneous [ . opening. During periods when containment is not required to be ! OPERABLE, 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. The emergency air. lock, l which is located in the equipment hatch opening, is normally removed ! from the containment building and stored during a refueling outage. ( Each air lock door has been designed and tested to certify its ; ability to withstand a pressure in excess of the maximum expected , pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY. Each of the doors contains double o-ring seals and local leakage 3 rate testing capability to ensure pressure integrity. DBA conditions which increase containment pressure will result in } increased sealing forces on the personnel air lock inner door and both doors on the emergency air lock. The outer door on the personnel air lock is periodically tested in a manner where the - containment DBA pressure is attempting to overcome the door sealing : forces. The containment air locks form part of the containment pressure l boundary. As such, air lock- integrity and leak tightness is { essential for maintaining the containment leakage rate within' limits in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analyses. SR 4.6.1.2 leakage rate requirements comply with 10 CFR 50, Appendix J, as modified by approved , exemptions.

APPLICABLE SAFETY ANALYSES .

i The DBAs that result in a release of radioactive material within ! containment are a loss of coolant accident and a rod ejection i accident. In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products , to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage l rate of 0.1 percent of containment air weight per day. This leakage rate is defined in 10 CFR 50, Appendix J, as L a = 0.1 percent of containment air weight per day, the maximum allowable containment leakage rate at the calculated peak containment internal pressure . i BEAVER VALLEY - UNIT 1 (Proposed Wording) l l

                                                  ~, - -

Attachment to " Containment Air Locks" (Continued) t INSERT "E" , n APPLICABLE SAFETY ANALYSES (Continued) ; r P = 40.0 psig following a DBA. This allowable leakage rate forms t$e basis for the acceptance criteria imposed on the SRs associated ' with the air locks. , F LCO Each containment air lock forms part of the containment pressure boundary. As part of containment, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to be ! considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a ningle door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into and exit from containment. APPLICABILITY In Modes 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and ; temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9.4, - " Containment Building Penetrations." ACTIONS The ACTIONS are modified by a General Note (1) that allows entry and exit to perform repairs on the affected air lock component. If the outer door is inoperable, then it may be easily accessed to repair. BEAVER VALLEY - UNIT 1 (Proposed Wording)

l

                      .                               .                                                           l Attachment      to " Containment Air Locks" (Continued)                                                I INSERT "E"

ACTIONS (Continued) .

If the inner door is the one that is inoperable, however, then a ; short time exists when the containment boundary may not be 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 i' in which the OPERABLE door is expected to be open. At no time should the OPERABLE door be opened if it cannot be demonstrated that the inoperable door is sufficiently closed / latched such that it could inadvertently open while the OPERABLE door is opened. After each entry and exit, the OPERAELE door must be immediately closed. , If ALARA conditions permit and personnel safety can be assured, i entry and exit should be via an OPERABLE air lock. General Note (2) has been added to provide clarification that, for ! this LCO, separate Action statement entry is allowed.for each air lock. , In the event the air lock leakage results in exceeding the combined containment leakage rate, General Note (3) directs entry into the Required Action of LCO 3.6.1.1.

a. With one air lock door in one or more containment air locks inoperable, the OPERABLE door must be verified closed j (Required Action a.1) in each affected containment air j lock. This ensures that a leak tight containment barrier !

is maintained by the use of an OPERABLE-air lock door. ; This action must be completed within 1 hour. This specified time period is consistent with the Renuired l Action of LCO 3.6.1.1, which requires CONTAINMENT INT) TY to be restored within 1 hour. In addition, the affected air lock penetration must be isolated by locking closed (Required Action a.2) the

OPERABLE air lock door within the 24 hour Completion Time.

The 24 hour Completion Time is reasonable for-locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained' closed. This action places additional positive controls on the use of the air lock when one air lock door is inoperable. Required Action a has been modified by a Note. Note (4) allows use of the air lock for entry and exit for 7 days , under administrative controls. Containment entry may be ' required to perform non-routine Technical Specification (TS) Surveillances and Required Actions, as well as other activities on equipment inside containment that are - BEAVER VALLEY - UNIT I (Proposed Wording)

Attachment to " Containment Air Locks" (Continued) INSERT "E" ACTIONS (Continued) required by TS or activities on equipment that support ! TS-required equipment. An example of such an activity would be the isolation of a containment penetration by at. least one operable valve, and the subsequent repair and post-maintenance technical specification surveillance ' testing on the inoperable valve. In addition, containment entry may be required to perform repairs on vital plant equipment which, if not repaired, could lead to a plant transient or reactor trip. This Note is not intended to preclude performing other activities (i.e., non-TS-required activities or repair of non-vital plant equipment) 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. Required Action a.3 verifies that an air lock with an , inoperable door has been isolate', by the use of a locked and closed OPERABLE air lock door. This ensures that an acceptable containment leakage boundary is maintained. The completion Time of once per 31 days is based on engineering ' judgment and is considered adequate in view of the low likelihood of a locked door being mispositioned. Required Action a.3 is modified by a Note (5) that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, it is unlikely that a door would become misaligned once it has been verified to be in the proper position.

b. With an air lock interlock mechanism inoperable in one or more air locks, the Required Actions and associated i Completion Times are consistent with those specified in Required Action a.

The Required Actions have been modified by two Notes. Note (6) allows entry into and exit from containment under the , control of a dedicated individual stationed at.the air lock l to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock). Note (5) applies to air lock doors located in high radiation , areas and allows these doors to be verified locked closed ! i BEAVER VALLEY - UNIT 1 (Proposed Wording) i l j

Attachment to " Containment Air Locks" (Continued) INSERT "E" ACTIONS (Continued) by use of adrdnistrative means. Allowing verification by-administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, it is unlikely that a door would become misaligned once it has been. verified to be in the proper position.

c. With one or more air locks inoperable for reasons other than those described in Required Actions a or b, Required Action c.1 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_ limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour (per LCO 3.6.1.1) 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 combined containment leakage rate can still be within limits.

Required Action c.2 requires that one door in the affected containment air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the Required Actions of LCO 3.6.1.1, which requires that CONTAINMENT INTEGRITY be restored within 1 ' hour. Additionally, Required Action c.3 requires that the affected air lock (s) must be restored to OPERABLE status within the 24 hour completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock. For all Required Actions, if the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not ! apply. To achieve this status, the plant must be brought to at j least MODE 3 within 6 hours and to MODE 5 within the following 30 ' hours. The allowed Completion Times are reasonable, based on , l operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems, i l BEAVER VALLEY - UNIT 1 (Proposed Wording)

i Ettachment to " Containment Air Locks" (continued) INSERT "E" SURVEILLANCE REOUIREMENTS (SR) Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of 10 CFR 50, Appendix J, as modified by approved exemptions. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The periodic testing requirements verify that the air lock leakage does not exceed -the allowed fraction of the- overall containment leakage rate. The Frequency is required by Appendix J, as modified by approved exemptions. Note (10) reflects the current approved exemption from Appendix J. Thus, SR 4.0.2 (which allows Frequency extensions) does not apply as stated in Note (7). Testing of the personnel air lock door seals may be accomplished with the air lock pressure equalized with containment or with atmospheric pressure. Each configuration- applies P , as a < minimum, across the sealing surfaces demonstrating the ability to function as designed. As long as the testing conducted is equivalent or more conservative than what might exist for accident l conditions, the air lock doors will be able to perform their design function. l ! Performance of maintenance activities which affect air lock sealing l capability, such as the replacement of the o-ring door seals and/or breach ring travel adjustment, will require performance of the appropriate surveillance requirements such as SR 4.6.1.3.a as a minimum. The . performance of SR 4.6.1.3.b will depend on the air lock components which are affected by the maintenance. Replacement of o-rings and/or breech ring travel adjustment on the inner i personnel air lock door, for example, normally will not require the performance of SR 4.6.1.3.b as a post maintenance test. Testing per SR 4.6.1.3.a is sufficient to demonstrate post accident leak j tightness of the inner air lock door. The sealing force, which is j applied to o-rings, is developed by the rotation of tapered wedges against the door's outer surface. This action forces the door to compress the o-rings which are located on the air lock barrel. When SR 4.6.1.3.a is performed, the area between the two concentric o-rings is pressurized to at least P a and a leak rate of the two o-rings and sealing surface is determined. This test pressure applies an opposing force to the breech ring closure force. Since the containment pressure developed during a DBA applies a closing l force which is supplemental to the breech ring force, the net result would be to improve the door sealing capability of the inner personnel air lock door over that which exists during the performance of SR 4.6.1.3.a. For this reason, performance of SR l l BEAVER VALLEY - UNIT 1 (Proposed Wording) I'

                                                                                                   - --i-.-.-,-,-iw<i
                              -mm.      -                        e                 -

                                                                                .1 o                                                                                    l Bttachment   to " Containment Air Locks" (Continued)                             !

INSERT "E" ! 1

 ~ SURVEILLANCE REOUIREMENTS (SR) (Continued) 4.6.1.3.b, which applies a force which opposes the breech ring force,   is not necessary following certain inner air lock door

maintenance. SR 4.6.1.3.a sufficiently demonstrates the ability of the inner air lock door to provide a leak tight barrier following maintenance affecting the door sealing surface. i Replacement of the o-rings on the outer personnel air lock door, ; which results in decreasing the breech ring closure force, will require performance of SR 4.6.1.3.b in addition to SR 4.6.1.3.a which is required due to the door being opened. This surveillance is required because containment DBA pressure tends to overcome the outer personnel air lock door sealing forces. Performance of SR l 4.6.1.3.a on the outer personnel air lock applies an opposing force 'l to the breech ring closure force in the same manner as previously l described for the inner personnel air lock door. However, for the ; outer personnel air door, the containment pressure developed during l a DBA applies an opening force which is opposing the breech ring. ! closure force. Therefore, upon completion of certain maintenance ; activities, continued outer door leak tightness during a DBA cannot [ be assured by performance of SR 4.6.1.3.a alone. Maintenance which ! may result in a decrease in closure force on any part of the door sealing surface, (decreasing of breech ring travel for example), , will require performance of SR 4.6.1.3.b. The performance of this , surveillance is necessary to ensure that containment DBA pressure l applied against the outer door will not result in the unseating of-the air lock door by overcoming of the breech ring closure forces to : the point where the leakage becomes excessive. Since SR 4.6.1.3.b duplicates DBA forces on the outer personnel air lock door and also l measures the air lock leakage rate, performance of this surveillance ' requirement demonstrates the continued _ ability of the outer personnel air lock door to provide a leak tight barrier, during a DBA, following specific maintenance activities. The air lock interlock is designed to prevent simultaneous opening , of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected ; post accident containment pressure, closure of either door will l support containment OPERABILITY. Thus, the door interlock feature i supports containment OPERABILITY and personnel safety, considering l the subatmospheric design, while the air lock is being used for I personnel transit in and out of the containment. Periodic testing f of this interlock demonstrates that the interlock will function as I designed and that simultaneous opening of the inner and outer doors I will not inadvertently occur. BEAVER VALLEY - UNIT 1 (Proposed Wording)

                                                                          'l Attachment  to " Containment Air Locks" (Continued)                          )

INSERT "E" l l SURVEILLANCE REOUIREMENTS (SR) (Continued) The SR has been nodified by two additional Notes. Note (8) states f that an inoperable air lock door does not invalidate the previous i successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of' providing a fission product barrier in the event of a DBA. Note (9) , has been added to this SR requiring the results to be evaluated against the acceptance criteria of LCO 3.6.1.2. This ensures that air lock leakage is properly accounted for in determining the combined containment leakage rate. I f i i 8 BEAVER VALLEY - UNIT 1 (Proposed Wording) ,

ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 a Proposed Technical Specification Change No. 66, Revision 1 i The following is a list of the affected pages: Affected Pages: I II ' XI 1-2 3/4 6-1 3/4 6-4 3/4 6-5 B 3/4 6-1 [ t r

  -~   .                          .                                      -                                                        .       . -

[- t i NPF-73 INDEX :( 4 J l DEFINITIONS SECTION PAGE 1 u

                                                                                                                                              .l i i

l l 1

1. 0 DEFINITIONS 1 1

1.1 DEFINED TERMS................................................ ...... 1-1

1. 2 THERMAL POWER......... ............................................. 1-1 1.3 RATED THERMAL POW:A .............. .......... ...................... 1-1 1.4 OPERATIONAL M00E... ......... ..................................... 1-1 l

1. 5 ACTI0N............................................................... 1-1 !

1. 6 OPERABLE - OPERABILITY.................... . ....................... 1 1.7 REPORTABLE EVENT.......................................... ......... 1-1

1. 8 CONTAINMENT INTEGRITY............. ....................... ......... 1-1

1. 9 CHANNEL CALIBRATION............................ ...... . ..... ..... 1-2 1.10 CHANNEL CHECK.............. ....................... ................ 1-2 1.

l 1 1.11 CHANNEL FUNCTIONAL TEST.................... ........................ 1-2 1.12 CORE ALTERATION............................................. ....... 1-2 ! 1.13 SHUTDOWN MARGIN. ............................. .... ... ............ 1-)S(5) 1.14 IDENTIFIED LEAKAGE............................. ......... .......... 1-3 1.15 UN I D ENTI F I ED LEA KAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3 1.16 PRESSURE BOUNDARY LEAKAGE......................... .... ...... ..... 1-3 1.17 CONTROLLED LEAKAGE......................... .. ... ................. 1-3 1.18 QUADRANT POWER TILT RATI0...................... ... .... ........ .. 1-3 1.19 DOSE EQUIVALENT I-131........... ..... ...... .................. .. 1-)f(D 1.20 STAGGERED TEST BASIS.................. ................ ...... . .. 1-1.21 FREQUENCY NOTATION................. .. ................. .......... 1-4 1.22 REACTOR TRIP RESPONSE TIME............. ............................ 1-4 1.23 ENGINEERED SAFETY FEATURE RESPONSE TIME................... ......... 1-4 1.24 AXIAL FLUX DIFFERENCE............................. ......... ....... 1-4 1 i i 1.25 PHYSICS TEST........................................................ 1-K i 1.26 E-AVERAGE DISINTEGRATION ENERGY............. ............ ....... . 1-1.27 SOURCE CHECK...................... ..................... ... .... . 1-5 1.28 PROCESS CONTROL PROGRAM..... . ........ ........ ........ ........ 1-5 1.29 SOLIDIFICATION............ .'........ ...... ...... ....... ...... .. 1-5 'l l l 1.30 0FF-SITE DOSE CALCULATION MANUAL (00CM)...... ............. ... .. . 1-5 ! i O % BEAVER VALLEY - UNIT 2 I i

NPF-73~ < INDEX : DEFINITIONS ,, i SECTION PAGE 1.31 GASEOUS RADWASTE TREATMENT SYSTEM....... ..................... . 1-5 l. 1.32 VENTILATION EXHAUST TREATMENT SYSTEM....... .................... 1-1 1.33 PURGE - PURGING............................. ................... 1 'il > @ 1.34 VENTING.......................................................... 1-6 1.35 MAJOR CHANGES................................................ . 1-6 1.36 MEMBER (S) 0F THE PUBLIC......................................... 1'S.40 TABLE 1.1 OPERATIONAL MODES (TABLE 1.1).............................. 1-Y @ ] TABLE 1.2 FREQUENCY N0TATION................................... ... . 1-X Q

                                                                                             ^1 l

l l 1 i i l l l I S'opO & s BEAVER VALLEY - UNIT 2 II j

L NPF-73 INDEX , BASES I I SECTION PAGE 3/4.4.6 REACTOR COO LANT SYSTEM LEAKAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 4-4 3/4.4.7 CHEMISTRY.................................................. B 3/4 4-5 3/4.4.8 SPECIFIC ACTIVITY.....................................-..... B 3/4 4-5 . 3/4.4.9 PRESSURE / TEMPERATURE LIMITS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 4-6 , 3/4.4.10 STRUCTU RAL INTEGRITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 4-15 1 3/4.4.11 RELIEF VALVES...................... ................ ..... B 3/4 4-16 3/4.4.12 REACTOR COOLANT SYSTEM HEAD VENTS.......................... B 3/4 4-16 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) . 3/4.5.1 ACCUMULATORS............................................... B 3/4 5-1 3/4. 5. 2 AND 3/4. 5. 3 ECCS SUBSYSTEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 5-1 3/4.5.5 (MOVED TO BASES SECTION 3/4.1.2) 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT........................................ B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS.............. ....... S 3/4 6 'S ,o 3/4.6.3 CONTAINMENT ISOLATION VALVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3/4 6-4' 3/4.6.4 COMBUSTIBLE GAS CONTROL........... ....................... B 3/4 6-3 ' 3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM..................... B 3/4 6-1 1 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE.............................................. B 3/4 7-1, 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION........... B 3/4 7-3 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM..................... B 3/4 7-3 3/4.7.4 SERVICE WATER SYSTEM...... ................................ B 3/4 7-3 3/4.7.5 ULTIMATE HEAT SINK. ..................................... . B 3/4 7-3 l 3/4.7.6 FLOOD PROTECTION......................... ................. B 3/4 7-4 3/4.7.7 CONTROL ROOM EMERGENCY MABITABILITY SYSTEM................. B 3/4 7-4 3/4.7.8 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS).... B 3/4 7-4 3/4 7.9 SEALED SOURCE CONTAMINATION............... ................ B 3/4 7 c 3/4.7.12 SNUBBERS........................................ .......... B 3/4 7-5 l ( yt0th Obr m BEAVER VALLEY - UNIT 2 XI i i

NPF-73 DEFINITIONS t CONTAINMENT INTEGRITY (Continued)

b. Closed by manual valves, blind flanges, or deactivated auto- ,

matic valves secured in their closed positions, except as - provided in Table 3.6-1 of Specification 3.6.3.1. 1.8.2 All equipment hatches are closed and sealed.<, q) ca.E n 1.8.3 Each air lock is GPERABL4-pursuantr-te Specification 3.6.1. , . and Q c g n.,,cc w h % p,g ce%u43oJ] l 1.8.4 The containment leakage rates are within the limits of l Specification 3.6.1.2 g , 1.8.5 The sealing mechanism associated with each penetration (e.g., , welds, bellows, or 0-rings) is OPERABLE. j CHANNEL CALIBRATION

1. 9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL !

CALIBRATION may be performed by any series of sequential, overlapping, or total l channel steps such that the entire channel is calibrated. ! j CHANNEL CHECK ! 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operatica by observation.- This determination shall include, where .1 possible, comparison of the channel indication and/or status with other indi-cations and/or status derived from independent instrument channels measuring the same parameter. CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions. CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the , vessel. Suspension of CORE ALTERATIONS shall not preclude completion of move- i ment of a component to a safe conservative position. SHUTDOWN MARGIN 1.13 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is or would be subcritical from its present condition assuming all full length rod cluster assemblies (shutdoon and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn. (froposch vu ort% BEAVER VALLEY - UNIT 2 1-2

NPF-73 3/4.6 CONTAINMENT SYSTEMS

          '3/4.6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION                                          __

3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained. APPLICABILITY: MODES 1, 2, 3 and 4. ACTION: Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 36 hours. SURVEILLANCE REOUIREMENTS 4.6.1.1 Pr'imary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that:

1. All penetrations capable of being closed by OPERABLE contain-ment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except ;

as provided in Table 3.6-1 of Specification 3.6.3.1.

2. All equipment hatches are closed and sealed.

b. By verifying that each containment air lock is OPERABLE pd (

Specification 3.6.1.3. g h cc%phawcc w Ah 4ht repwemd3 of)- ho TnSERTD G W M xcept E valves, blind flanges, and deactivated automatic valves which are located inside the containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days. (Preposd Werb[ BEAVER VALLEY - UNIT 2 3/4 6-1

Attachment to " Containment Intecrity"

INSERT "F"

c. After' each closing of each penetration' subject to Type B testing, except the containment- air. locks, if opened i following a Type A or B test, by leak rate testing the seal with gas at a pressure not less than P a (44 7 Psig), and ,

verifying that _w hen the measured leakage rate for these . seals is added to the leakage rates determined-pursuant-to , Specification 4.6.1.2.d for all other Type 'B and C penetrations, the combined leakage rate is less than 0.60 L a* 7 v i

l i l l BEAVER VALLEY ~- UNIT 2 (Proposed Wording) 1 l

NPF-73 CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIMIIlHG_f0NDITION FOR OPERATION too ELETE

3. 6.1. 3 containment air lock shall be OPERABLE :

a. Both dccrs closed except-when--the air lock is being used for neraal trarcit entry end exit through the contai-: cat, then at hast cne ai- lock deer :hel' be closedy-and 01 LET4

b. An overal4-c4r Sck bakage rate Of hss-than er equal to 0.05 L at

                            -Pa (14* ? P3iUY' APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION: n ,a 4 (400 TuSERT G )

a. With one containment air lock door inoperable +Qrsewoormere e<4um\ a clec

      . ., o                1.       eintoift-the-essee4ated CPEPf2LE ch h:.L do:r ch:;c ' md    g, e4ther-restere-the-eesec4cted incperch ci, hek de,:.,c to d**# G M $d*

t GPERACLE states within 24 heurs cr+ Lock the a :cciated-OPER LE a % bjasctecR q w .%n 1 gg sir Sck door closed. Q ~

                                                       .      hk' b~N **          O"Oh.

Operat4cn acy then continue untH performcacc of the ackt to

                                                                                                * , , es BLE 3'          required-over:l' cir-locA-Teakage-teet provided that the (doer tsj

cciated OPE?J3LE air lack decr is werified to be locked closed.at least once per 31 days. i Gw he ah61 aie loco N Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

REdL>,tE Ctyg . eORETE -

WSEf,T B - Ih0 PiOVUICO3 OI SP00If4<0tiOO 3*0*' OTO COI OPPIICODIO \

b. With a containment air lock inoperable, except as a result of an inoperable air lock door, mahtain at least one air lock door closed; restore the inoperabie air lock to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

Ano N (m sq .4 wh tr recris3 Me 6r %ys u4e ab,wabboc coabd '

                                .a p ,.t oebdo wA rAbd b h cerair of aMd a' eld'a r (5) A# bcR chor.s tw b b ~A sdien ateus % b utriE'ed locM c 6 se 4 1,   o b swis b '" ****s .

o h Q)c,k ok CCm\m%t ' ( {g 3 f*I deLded ma vA \.

                                      ^
                                                         & 3746-4Jtoed,O]                                       ;

BEAVER VALLEY - UNIT 2

Attachment to " Containment Air Locks" INSERT "G" , - - - - - - - - - - - - - GENERAL NOTES - - - - - - - - - - - - - - ;

1. Entry and exit is permissible' to perform repairs on the- ;

affected air lock components.

2. Separate ACTION statement entry is allowed for each air

lock.

3. Enter the ACTION of LCO 3.6.1.1, when air lock leakage ,

results in exceeding the combined containment leakage rate. i INSERT "H" ,

b. With the containment air lock interlock inoperable in one or more containment air locks:(6) mechanism

1. Verify an OPERABLE door is closed in tha affected air lock within 1 hour, and

2. Lock an OPERABLE door closed in the affected air lock-within 24 hours, and t

3. Verify an OPERABLE door is locked clos 9 in the affectedairlockatleastonceper31 days.Lg)

4. Otherwise, be in at least HOT STANDBY within the next I hours and in COLD SHUTDOWN within the following 30 hiurs.

c. With one or mor cv :ainment air locks inoperable, except as the result ri nr- inoperable air lock door and/or i inoperable interlo ar:hanism:

Immediately initiate action to evaluate the combined- ! 1. containment leakage rate per LCO 3.6.1.2, and

2. Verify a- door is closed in each affected air lock, within 1 hour, and

3. Restore the air lock to' OPERABLE status within 24 '

hours. ,

4. Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

BEAVER VALLEY - UNIT 2 (Proposed Wording) l

NPF-73 CONTAINMENT SYSTEMS ! SURVEILLANCE REOUIREMENTS l 4.6.1.3 Each containment ir lock shall be demonstrated OPERABLE:

a. Within 72 hourf following each containment entry, except when the air lock is being used for multiple entries, then at least once per l 72 hours? by verifying no detectable seal leakage when the gap :

between the door seals is pressurized for at least 2 minutes to: 1 r

1. Personnelairlockyf4.7psig l

                                                                           .c An .c ep\ 4.]

2. Emergencyairlock[0.0psig !

REA. ACE turrH TNSERT

f. n or, by quantifying requirements the total of 3.6.1.3.b air lock leakage to insure the]

are met. w a

b. By conducting overall air lock leakage tests,*at not less than P !

(44.7 psig), and verifying the overall air lack leakage rate is # ~ Sith " it:rli;iti di'53 b o 3M h c . e f 1. , d 9 , M g '

1. At least once per 6 months,'fpand Ifrische e1ib%sh '

m L CoHT%irmENT ;:r :n;1:ti:n ;" maintenance wM4h has been performed on e-Lwbw_ air lock snat could affect the air lock sealing capabi i I c. At least once per 18 months during shutdown verifying: DELETE - !

1. Only one door in each air lock can be opened at a time. i e

(2. -- a:ec;es;e ;;;l 1:2:;; .;h;r th; v;1=: 5 t :n th: :::rg h j l , ai" ! @ theft res!! is pressurized te gn:ter th r. Or :;u:1 to i ! AA 7 g{g fgg gg }gggt ] gjpgygg. DELETE A 5.A .- % ar e.ma me

                                                                     ~..h - ec r d . h M it T U I S s. u y'A t / M d e'? a .r w . A r M       Aw mo 4 =chcK a=c4*e "A m M a b r * *"3 sucessk\ pken.mee a t. %. ear.\\ . , \.& 1,.vg 44.

N=3whS SM he. egakua\d ag mak N'ocup4=nce. 09tria el LCO O'6*l

                     /                                                                                        !

1 O W X The provisions of Specification 4.0.2 are not applicable. N g Exemption ppendix J of 10 CFR 50 h as 34. led m 4% oys bcevoe BEAVER VALLEY - UNIT 2 3/4 6-5 (thp Na

I 1 Attachment to " Containment Air Locks" j INSERT "I" I or, by quantifying (8) the air l'ock door seal leakage to ensure : that the leakage rate is less than or equal to 0.0005 La at ! P (44.7 psig) for the . personnel air lock and 0.0005 L a at ! 18.0 psig for the emergency air lock. ! lI [ l i i i

                                                                            .h i

i ( i t I i

                                                                          .1 f

l

                                                                         -f
                                                                           -r I
                                                                          =!

' BEAVER VALLEY - UNIT 2 (Proposed Wording) f

NPF-73 i 3/4.6 CONTAINMENT SYSTEMS BASES ! 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY - Primary CONTAINMENT INTEGRITY ensures that the release of radioactive , ,, materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with the leakage rate limitation, will limit the , site boundary radiation doses to within the limits of 10 CFR 100 during ' accident conditions. 3/4.6.1.2 CONTAINMENT LEAKAGE l The limitations on containment leakage rates ensure that the total

containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure, P,. As an added conservatism, the measured overall integrated leakage rate is further limited to < 0.75 La during performance of the periodic test to account for possible degradation of '

the containment leakage barriers between leakage tests. The surveillance testing for measuring leakage rates are consistent with the requirements of Appendix "J" of 10 CFR 50. REi%CE W \TH $NSEWW 3/4.6.1.3 CONTAINMENT AIR LOCKS h The limitations on closure and leak rate for the containment air locks are required to meet the restrictions on CONTAINMENT INTEGRITY and containment leak rate. Surveillance testing of the air lock seals provides assurance that the overall air lock leakage will not become excessive due to seal damage ;

  . during the intervals between air lock leakage tests.

k 3/4.6.1.4 and 3/4.6.1.5 INTERNAL PRESSURE AND AIR TEMPERATURE ) The limitations an containment internal pressure and average air temperature as a function of service water temperature ensure that 1) the containment-structure is prevented from exceeding its design negatise pressure of 8.0 psia, i

2) the containment peak pressure does not exceed'the design pressure of 45 psig !

during LOCA conditions, and 3) the containment pressure is returned to sub-atmospheric conditions following a LOCA. ' The containment internal pressure and temperature limits shown as a r function of service water temperature describe the operational envelope that will 1) limit the conta Mment peak pressure to less than its design value - i BEAVER VALLEY - UNIT 2 B 3/4 6-1 Amendment No. I ( Pre p sed % e

Attachment to " Containment Air Locks" INSERT "J" l l l BACKGROUND Containment ' air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation. Each air lock is nominally a right circular cylinder, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, 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. The emergency air lock, which is located in the equipment hatch opening, is normally removed o from the containment building and stored during a refueling outage. l Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of'the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY. Each of the doors contains double o-ring seals and local leakage rate testing capability to ensure pressure integrity. .DBA conditions which increase containment pressure will result in increased sealing. forces on the personnel air lock inner door and both doors on the emergency air lock. The outer door on the personnel air lock is periodically tested in a manner where the containment DBA pressure is attempting to overcome the door sealing forces. The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limits in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analyses. SR 4.6.1.2 leakage rate requirements comply with 10 CFR 50, Appendix J, as modified by approved exemptions. APPLICABLE SAFETY ANALYSJji The DBAs that result in a release of radioactive material within containment are a loss of coolant _ accident 'and a rod _ ejection. accident. In the analysis of each of these accidents, it is assumed' that containment is OPERABLE such that release of fission products-to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.1 percent of containment air weight per day. This leakage rate is defined in 10 CFR 50, Appendix J, as L a =,0.1 percent of containment air weight per day, the maximum allowable containment leakage rate at the calculated peak containment internal pressure BEAVER VALLEY - UNIT 2 (Proposed Wording) ,

~ - u.4 >pai d e s _.~m#

Attachment to " Containment Air Locks" (Continuedl > INSERT "J" APPLICABLE SAFETY ANALYSES (Continued)

      .P      =   44.7          psig following a DBA. This allowable leakage rate forms                      i t$e ' basis
                                                                                                             ~

for the acceptance criteria imposed on the SRs associated with the air locks. i LCO Each containment air lock forms part of the containment pressure ! boundary. As part of containment, the air lock safety function is , related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural. integrity and leak tightness are essential to the successful mitigation of such an event, j Each ' air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air , lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross. breach of containment does not exist when containment is required to be ; OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. i Nevertheless, both doors are kept closed when.the air lock is not being used for normal entry into and exit from containment. t APPLICABILITY ! In Modes 1, 2, 3, and 4, a DBA could cause a release of radioactive material -to containment. In MODES 5 and 6, the probability and ' consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment . air locks- are not required in MODE 5 to prevent leakage of ! radioactive material from containment. The requirements for the containment air locks during . MODE 6 are addressed in LCO 3.9.4, l

       " Containment Building Penetrations."                                                                 -

ACTIONS i The ACTIONS are modified by a General Note (1) that allows entry and l exit to perform repairs on the affected air lock component. If.the . outer door is inoperable, then it may be easily accessed:to repair. .!3 r BEAVER VALLEY - UNIT 2 (Proposed Wording) f

                                            ,-           . , . .   , . . , ,        . . . , - - - ...n,

l Attachment to'" Containment Air Locks" (Continued) INSERT "J" r l i ACTIONS (Continued) l i If the inner door is the one that is inoperable, however, then a ) short time exists when the containment boundary may not be intact i (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. At no time should the OPERABLE door be opened if it cannot be demonstrated that the inoperable door is sufficiently closed / latched such that it could inadvertently open while the OPERABLE door is opened. After i cach entry and exit, the OPERABLE door must be immediately closed. l If ALARA conditions permit and personnel safety can be assured, I entry and exit should be via an OPERABLE air lock. , i General Note (2) has been added to provide clarification that, for j this LCO, separate Action statement entry is allowed for each-air l lock.

                                                                                         .l In the event the air lock leakage results in exceeding the combined                      J containment leakage rate, General Note (3) directs entry into the Required Action of LCO 3.6.1.1.

a. With one air lock door in one or more containment air locks inoperable, the OPERABLE door must be _ verified closed (Required Action a.1) in each affected containment air lock. This ensures that a leak tight containment barrier is maintained by the use of an OPERABLE air lock door.

This action must be completed within 1 hour. This specified time period is consistent with the Required Action of LCO 3.6.1.1, which requires CONTAINMENT INTEGRITY to be restored within 1. hour. In addition, the affected air lock penetration must be isolated by locking closed (Required Action a.2) the OPERABLE air lock door within the 24 hour Completion Time. The 24 hour Completion Time is reasonable for locking the OPERABLE air lock door, considering.the. OPERABLE door of the affected air lock is being maintained closed. This , action places additional positive- controls on the use of i the air lock when one air lock door is inoperable. Required Action a has been modified by a Note.. Note (4) allows use of the air lock for' entry and exit for 7 days under administrative controls. Containment entry may be. required to perform non-routine Technical Specification (TS) Surveillances and Required Actions, as well as other activities on equipment inside containment that are I I BEAVER VALLEY - UNIT 2 (Proposed Wording) ! l

i Attachment to " Containment Air Locks" (Continued) l INSERT "J"

                                                                               )
                                                                             -l ACTIONS (Continued) required by TS       or activities on equipment that support TS-required equipment.         An example of such an activitf would be the isolation of a containment penetration by at L          least one operable valve, and the subsequent repair and post-maintenance        technical   specification     surveillance testing on the inoperable valve.         In addition, containmen'.

entry may be required. to perform repairs on vital plant ~ equipment which, if not repaired, could lead to a plant , transient or reactor trip. This Note is not intended to l preclude performing other activities (i.e., non-TS-required i activities or repair of non-vital plant equipment) 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 I could . pressurize the containment during the short time that the OPERABLE door is expected to be open. Required Action a.3 verifies that an air lock with an inoperable door has been isolated by the use of a locked and closed OPERABLE air lock door. This ensures that an 4 acceptable containment leakage boundary is maintained. The l Completion Time of once per 31 days is based on engineering judgment and is considered adequate in view of the low ! likelihood of a locked door being mispositioned. Required l Action a.3 is modified by a Note (5) that applies to air i lock doors located in high radiation areas and allows these ! doors to be verified locked closed by use of administrative j means. Allowing verification by administrative means is considered acceptable, since access to. these . areas is i typically restricted. Therefore, it is unlikely that a j door would become misaligned once it has been verified to be in the proper position,

b. With an air lock interlock mechanism inoperable in one or ;

, more air locks, the Required Actions and associated ' I Completion Times are consistent with those specified in i Required Action a. l The Required Actions have been modified by two Notes. Note I l (6) allows entry into and. exit from containment under the l l 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). Note (5) applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed i BEAVER VALLEY - UNIT 2 (Proposed Wording)

Attachment to " Containment Air Locks" (Continued) INSERT "J" ACTIONS (Continued) by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, it is unlikely that a door would become misaligned once it has , been verified to be in the proper position.

g. With one or more air locks inoperable for reasons other than those described in Required Actions a or b, Required- ,

Action col 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 combined air lock leakage is not within limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE,'yet only 1 hour (per LCO 3.6.1.1) 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 combined containment leakage rate can still be within limits. Required Action c.2 requires that one. door in the affected containment air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the Required Actions of LCO 3.6.1.1, which requires that CONTAINMENT INTEGRITY be restored within 1 hour. Additionally, Required Actisn c.3 requires that the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock. For all Required Actions, if the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within the following 30 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. BEAVER VALLEY - UNIT 2 (Proposed Wording)

Attachment to " Containment Air Locks" (Continued)- - INSERT "J" SURVEILLANCE REOUIREMENTS (SR) Maintaining containment air locks OPERABLE requires compliance with , the leakage rate test requirements of 10 CFR 50, Appendix J, as modified by approved exemptions. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The periodic testing requirements verify that the air lock

leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by Appendix J, as modified by approved exemptions. Note (10) reflects the current approved exemption from Appendix J. Thus, SR 4.0.2 (which allows Frequency extensions) does not apply as stated in Note (7).

Testing of the personnel air lock door seals may be accomplished i with the air lock pressure equalized with containment or with atmospheric pressure. Each configuration applies P, as a l' minimum, across the sealing surfaces demonstrating the ability to ' function as designed. As long as the testing conducted is equivalent or more conservative than what might exist for accident ' conditions, the air lock doors will be able to perform their design

function.

Performance of maintenance activities which affect air lock sealing capability, such as the replacement of the o-ring door seals and/or breach ring travel adjustment, will require performance of the appropriate surveillance requirements such as SR 4.6.1.3.a as a minimum. The performance of SR 4.6.1.3.b will depend on the air , lock components which are affected by the maintenance. Replacement of o-rings and/or breech ring travel adjustment on the inner personnel air lock door, for example, normally will not require the i performance of SR 4.6.1.3.b as a post maintenance test. Testing per j SR 4.6.1.3.a is sufficient to demonstrate post accident leak tightness of the inner air lock door. The sealing force, which is applied to o-rings, is developed by the rotation of tapered wedges against the door's outer surface. This action forces the door to i compress the o-rings which are locateu on the air lock barrel. When SR 4.6.1.3.a is performed, the area between the two concentric ) o-rings is pressurized to at least P a and a leak rate of the two i o-rings and sealing surface is determined. This test pressure applies an opposing force to the breech ring closure force. Since , the containment pressure developed during a DBA applies a closing l force which is supplemental to the breech ring force, the net result- ; would be to improve the door sealing capability of the inner J door over that which exists during the personnel air lock l performance of SR 4.6.1.3.a. For this reason, performance of SR

BEAVER VALLEY - UNIT 2 (Proposed Wording) I I

Attachment to " containment Air Locks" (Continued) INSERT "J" SURVEILLANCE REOUIREMENTS (SR) (Continued) l 4.6.1.3.b, which applies a force which opposes the breech ring l force, is not necessary following certain inner air lock door maintenance. SR 4.6.1.3.a sufficiently demonstrates the ability of the inner air lock door to provide a leak tight barrier following maintenance affecting the door sealing surface. Replacement of the o-rings on the outer personnel air lock door, which results in decreasing the breech ring closure force, will- ' require performance of SR 4.6.1.3.b in addition to SR 4.6.1.3.a which is required due to the door being opened. This surveillance is required because containment DBA pressure tends to overcome the outer personnel air lock door sealing forces. Performance of SR 4.6.1.3.a on the outer personnel air lock applies an opposing force to the breech ring closure force in the same manner as previously described for the inner personnel air lock door. However, for the outer personnel air door, the containment pressure developed during l a DBA applies an opening force which is opposing the breech ring ; closure force. Therefore, upon completion of certain maintenance activities, continued outer door leak tightness during a DBA cannot be assured by performance of SR 4.6.1.3.a alone. Maintenance which may result in a decrease in closure force on any part of.the door sealing surface, (decreasing of breech ring travel for example), I will require performance of SR 4.6.1.3.b. The performance of this ; surveillance is necessary to ensure that containment DBA pressure / applied against the outer door will not result in the-unseating of the air lock door by overcoming of the breech ring closure forces to the point where the leakage becomes excessive. Since SR 4.6.1.3.b : duplicates DBA forces on the outer personnel air lock door and also ! measures the air lock leakage rate, performance of this surveillance ! requirement demonstrates the continued ability of the outer personnel air lock door to provide a leak tight barrier, during a DBA, following specific maintenance activities. The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum-expected post accident containment pressure, closure of either door will , support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY and personnel safety,.considering the subatmospheric design, while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as' designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. l BEAVER VALLEY - UNIT 2 (Proposed Wording)

Attachment to " Containment Air Locks" (Continued) INSERT "J" r SURVEILLANCE REOUIREMENTS (SR) (Continued) The SR has been modified by two additional Notes. Note (8) states . that an inoperable air lock door does not invalidate the previous a successful performance of the overall air lock leakage test. This i is considered reasonable since either air lock door is capable of ; providing a fission product barrier in the event of a DBA. Note (9) ! has been added to this SR requiring the results to be evaluated against the acceptance criteria of LCO 3.6.1.2. This ensures that , air lock leakage is properly accounted for in ' determining the combined containment leakage rate. ! i a i BEAVER VALLEY - UNIT 2 (Proposed Wording) l

ATTACHMENT B l Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 199 and 66, Revision 1 REVISION OF SPECIFICATION 3.6.1.1 TITLED " CONTAINMENT INTEGRITY," SPECIFICATION 3.6.1.3 TITLED " CONTAINMENT AIR LOCKS" AND ASSOCIATED BASES AND DEFINITION OF CONTAINMENT INTEGRITY l l l l A. DESCRIPTION OF AMENDMENT REQUEST The proposed change would revise Section 1.0 titled

   " Definitions."      The specific revision       would be to revise item   i 1.8.3 under the Containment Integrity            definition. Item 1.8.3 would be modified by replacing the words " OPERABLE pursuant to" with the words "in compliance with the requirements of." In addition,     for Beaver Valley Power Station (BVPS) Unit No. 1 only, a new item 1.8.5 would be added which pertains to sealing mechanisms.       This item currently exists as item 1.8.5 in BVPS Unit No. 2's definition of " containment integrity."

Limiting Condition For Operation (LCO) 3.6.1.1 would be revised to include a new Surveillance Rr7uirement (SR) 4.6.1.1.c. This new SR would require re-testing oi penetrations subject to Type B leak testing if they are opened following a Type A or B test. , The new leak rate would then be required to be factored into the total combined containment leakage rate. In addition, the current SR 4.6.1.1.b would be modified by replacing the words

   " OPERABLE     per" with the words           "in compliance with the requirements of."         The  existing footnote  designated by a single asterisk would be designated by the number one.

The proposed change would also revise LCO 3.6.1.3 titled :

   " Containment    Air Locks."       The word "each" would be replaced by    '

the word "two." LCO 3.6.1.3, items "a" and "b," would be relocated. Item "a" will be incorporated into the LCO Bases. Item "b" will be incorporated into the requirements of SR 4.6.1.3. The action statement of LCO 3.6.1.3 would be revised by adding three new general notes. Note (1) allows entry and exit into an air lock to perform repairs. Note (2) states that separate action statement entry is allowed for each air lock. Note (3) requires entry into the action statement of LCO 3.6.1.1 ' when the air lock leakage rate results in exceeding the combined containment leakage rate. Action statement "a" would be modified to reflect the condition when one or more air locks are affected by an inoperable door. A new footnote designated by the number four would be added which permits entry and exit for 7 days under administrative controls to perform activities not related to the repair of affected air lock components. Action statement "a.1" would be modified to require verification that an operable door is closed in the affected air lock within i hour. In addition, the existing requirement to lock the associated operable air lock door closed f B-1

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 t Page 2 would be separated from "a.1" and exist as "a.2." Existing action statement "a.2" would be modified by deletion of the words pertaining to continued operation until performance of the next- required overall air lock leakage test and by the addition of a new footnote designated by the number five. Footnote (5) would allow the 31 day verification,.that an air lock door is , locked, to be performed by administrative means. This action statement would be renumbered as "a.3" and the existing "a.3" renumbered as "a.4." Also, the exemption to Specification 3.0.4 would be deleted. i A new action statement "b" would be added to provide guidance for the condition where the air lock interlock mechanism is inoperable. A new footnote (6) would be added which would allow entry and exit of containment, through an air lock with an inoperable interlock mechanism. This evolution would be permitted provided that a dedicated individual ensures that one air lock door is maintained closed. The existing action statement "b" would be modified and bc designated action statement "c." The modifications to existing action statement "b" would include the addition of words which reflect the condition when one or more air locks are inoperable, except as the result of an inoperable air lock door and/or inoperable interlock mechanism. A new requirement would be added which requires an evaluation of the combined containment leakage rate per LCO 3.6.1.2. Also, a requirement would be added to y verify a door is closed in each affected air lock within one hour. SR 4.6.1.3.a would be revised. by addition of footnote (7). Footnote (7) is currently designated as the pound symbol and will ; no longer apply to SR 4.6.1.3.b.1. The existing words in SR 4.6.1.3 "or, by quanc.ifying the total air lock leakage to ensure the requirements of 3.6.1.3.b are met" would be replaced. t The proposed wording wou".a allow the door seal leakage to be quantified to ensure that the leakage rate is less than or equal , to 0.0005 L. A new footnote (8) would be applied to this proposed wor 8ing on quantifying door leakage. Footnote (8) would state that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. The symbols "2" would be replaced with the words " greater than or equal to." SR 4.6.1.3.b would be revised by the addition of a new footnote , (9) which requires that the results of the overall air lock leakage test be evaluated against the acceptance criteria of LCO 3.6.1.2. The words "within its limit" would be replaced with the words "less than or equal to 0.05 L at P " with the specific pressure designated for each Unit. Sk 4.6.1.$.b.2 would B-2

ATTACHMENT B, continued Proposed Technical Specificati,n Change Nos. 199 and 66, Revision 1 Page 3 l be revised by replacing the words "Upon completion of" with the words " Prior to establishing CONTAINMENT INTEGRITY when." The footnote pertaining to the exemption to Appendix J would be designated by the number (10). Additionally, this footnote would be modified, for BVPS Unit 2 only, by the addition of the words "as stated in the operating license." A new SR 4.6.1.3.b.3 would be added and would state the following: ."Following maintenance performed on the outer personnel air lock door which may result in a decrease in closure force on any part of the door sealing surface." SR 4.6.1.3.c.2 would be deleted by this proposed change request. The Bases section for 3/4.6.1.3 titled " Containment Air Locks" would be expanded to reflect the applicable wording contained in NUREG 1431, Revision 0, titled " Standard Technical Specifications for Westinghouse Plants." The Index pages would be revised to reflect the page changes due to the various revisions associated with this change request. B. BACKGROUND Both BVPS Unit Nos. I and 2 have two separate containment air locks. Each air lock is a circular cylinder with doors at each end which are interlocked to prevent simultaneous opening. Since both Beaver Valley containments operate at subatmospheric pressure, the interlock provides personnel safety in addition to preventing a direct path out of containment. . Each air lock door has been designed and tested to certify its ability to withstand-a pressure in excess of the maximum expected pressure following a design basis accident (DBA) in containment. As such, closure of a single door assures that the containment is operable. Each of the doors contain double o-ring seals and local leakage testing capability to ensure pressure integrity. For an air lock to be considered operable, the air lock interlock mechanism must be operable, the air lock must be in compliance with Type B leakage limits, and both air lock doors must be operable. C. JUSTIFICATION These changes, in general, reflect the Improved Standard Technical Specifications contained in NUREG 1431, Revision O. The proposed revisions to item 1.8.3 under the Definitions : section and SR 4.6.1.1.b will permit entry into the action statements of LCO 3.6.1.3 and avoid the possibility of entering the action statement of LCO 3.6.1.1. The definition of containment integrity and the requirements of SR 4.6.1.1.b' require that the air lock be operable. Entry into any of the. action statements of LCO 3.6.1.3 can be interpreted that the air lock is inoperable in terms of the requirements of LCO 3.6.1.1 (i.e., containment integrity is not being maintained).- LCO 3.6.1.1 requires that the containment integrity be restored to operable within 1 hour or cold shutdown must be achieved within i B-3 l 1

-ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 4 the following 36 hours. The proposed revisions will allow compliance with the requirement of LCO 3.6.1.1 while in the action statements of LCO 3.6.1.3. This is consistent with the latest revision of NUREG 0452 (Standard Technical Specifications) where this potential for competing action statements was resolved. The proposed addition of item 1.8.5 under the definitions section, for BVPS Unit No. 1 only, will make both Unit's Technical Specifications (TS) consistent. Since the Unit No. 1 containment building contains mechanical and electrical penetrations which utilize o-ring seals, this requirement is applicable to Unit No. 1. The proposed addition of SR 4.6.1.1.c will ensure that penetrations subject to Type B leak testing, except for the air locks, are leak tested after being opened to demonstrate operability. This surveillance requirement is consistent with item 1.8.5 under the containment integrity definition. The proposed revisions to LCO 3.6.1.3 would reflect that BVPS Unit Nos. 1 and 2 each have two containment air locks (i.e., personnel air lock and emergency air lock). The current wording of LCO 3.6.1.3 action statements only pertains to a single component being inoperable. A condition where two doors on two separate air locks are inoperable is not addressed by the present LCO wording. The proposed change will clarify this configuration. Containment integrity will continue to be maintained with a single operable door in the closed position. A general note (1) would be added to LCO 3.6.1.3 to clarify that entry and exit is permissible through a closed or locked closed operable door for the purpose of repairing the affected air lock components. The LCO action statement requires that the remaining operable air lock door be maintained closed and locked closed after a 24 hour period has elapsed. If the inner air lock door is inoperable, then the outer door must be maintained locked closed and this would not permit the outer door to be opened at any time. Without the clarification provided by the proposed general note, repair of the inner door, for example, on the personnel air lock would pose additional safety risks and increased radiation exposure to maintenance personnel attempting a containment entry via the emergency air lock. The emergency air lock was added for safety concerns to provide a second means of egress from containment. Egress through the emergency air lock is possible, however, its function is to provide an emergency exit route. Under an emergency condition, rapid egress is required to facilitate medical treatment of injured personnel, if required. Therefore, the emergency air lock is designed to quickly equalize the differential pressure between the inside of the air lock and the outside atmosphere. This rapid equalization has resulted in ruptured ear drums and general personnel B-4

ATTACHMENT B, continued !' Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 5 i discomfort. Also,- personnel using the emergency air lock are exposed to higher radiation fields due to the lack of a shield wall between the air lock and the reactor vessel area. The containment crane wall, which provides shielding for the personnel air lock, is open in the area of the' emergency air lock. The proposed addition of general note (2) will clarify that , separate entry into the action statements for each airLlock is permitted and that the required action times are independent'for r each air lock. This change is necessary to specify that the , completion times for this LCO are on a component basis rather than a condition basis. Multiple entries into proposed, action statements "a," "b," or "c" for air ' locks with independent completion times does not represent degradation of containment leak tightness, only degradation of the entry and exit capabilities. In the event that tre condition of the air locks , represent degradation of the containment leak tightness, action will be taken in accordance with .LCO 3.6.1.1. The proposed general note (3) will ensure that the action statement of LCO 3.6.1.1 is entered when the air lock leakage rate results-in exceeding the combined containment leakage rate. LCO 3.6.1.1 is referenced in general note (3) in lieu. of LCO 3.6.1.2. LCO 3.6.1.1 action statement requires a plant shutdown in 36 i hours if its requirements are not- met. LCO 3.6.1.2's action statement only prohibits entry into Mode 4. This action statement would not be- appropriate for plant operation, i.e.,. Mode 1 through 4 operation. In addition, the definition of l containment integrity requires that containment leakage rates are within the limits of Specification 3.6.1.2. Therefore, if the-allowable containment leakage rate is exceeded due to excessive ; air lock leakage, containment integrity is no longer being maintained and therefore the action statement of LCO 3.6.1.1 is appropriate for this condition. Action statement "a" _would be modified by Note (4) which would-allow entry and exit through an air lock with an inoperable door for a 7-day period. This Note is necessary for the same reasons previously discussed for general note (1). However, this note ! allows entry and exit to perform activities not related to the ' repair of the air lock. These activities-could include the. repair of vital plant equipment- which,xif not-repaired, could' ; lead to a plant transient or reactor trip. In addition,. -j non-routine technical specification surveillances could be - required .to be performed inside the containment building. A-post-maintenance test of a reactor- coolant pressure isolation valve, in accordance with SR 4.4.6.3.1, is an example.of a ! non-routine technical specification surveillance which ;would require a containment entry. Therefore, Note (4)'would allow H containment entry and exit for 7 days to perform' these activities. The proposed modification to action statement "a.1"- will ensure that the operable door is verified to be closed within 1 hour. This will ensure that at least one leak tight. B-5 l

ATTACHMENT B, continued-Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 6 containment barrier is closed. Additionally, action statement "a.1" is further revised by separating into two action statements. Existing action statement "a.2" would be modified by deletion of the reference to performing the overall air lock leakage test. This reference is not necessary since. this requirement, to perform the overall air lock leakage test on a six month basis, is not waived by entering into the inoperable door action statement. Therefore, the overall air lock leakage test must continue to be performed on a six month frequency. This action statement would also be modified by the addition of footnote (5). This footnote allows the 31 day verification of the locked closed air lock door to be performed by administrative means for air lock doors located in high radiation areas. Since access to high radiation areas is restricted by plant administrative procedures and physical barriers, the probability of an air lock door being misaligned (i.e., not locked closed) once it has been verified to be in the proper position is low. Therefore, use of footnote (5) does not result in any significant increase in risk of door mispositioning. Action statement "a.4," which pertains to the exemption to Specification 3.0.4, would be deleted by this proposed amendment. This exception is no longer necessary due to the proposed revisions to action statement "a." Under Specification 3.0.4, mode entry is permitted if the associated actions _for the mode to be entered permit continued operation in the mode or specified condition for an unlimited period of time. The proposed revisions to action statement "a" reflect this situation and therefore the exception to Specification 3.0.4 is no longer required. The proposed addition of a new action statement "b" would provide compensatory measures in the event an air lock interlock mechanism is inoperable. Action statement "b" compensates for the interlock mechanism being inoperable by precluding any situation where the interlock would be required to operate. Administrative controls would be substituted for the design feature of the interlock. The administrative controls consist of locking closed one operable door and the use of a. dedicated individual, as required by footnote (6), to ensure that at least one operable air lock door is maintained closed should passage through the air lock be required. Footnote (5) is again applied to the 31 day verification of a locked closed door for the same reasons as previously discussed for action statement "a.2." A condition where the containment air lock interlock is' inoperable is not addressed by the present LCO wording. Since the plant is in a safe condition with the air lock interlock inoperable, passage through the air lock utilizing administrative. controls ensures that one air lock door is maintained closed and that containment integrity will continue to be maintained with a single operable door in the closed position. B-6

. ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 7 The proposed action statement "c" is a modification to the current action statement "b." Proposed action statement "c" reflects the- condition when the inoperability is not due to an inoperable air lock door and/or inoperable interlock mechanism. In addition, a new action requirement "c.1" has been added.which requires immediate initiation of an evaluation to ensure that the combination of the previous combined leakage rates and the current air lock test results does not result in exceeding the maximum allowable combined leak rate of 0.60 L a. 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 limits. In many. instances, the containment remains operable (i.e., the combined containment leakage rate does not exceed 0.60 L with the-overall air lock leakage rate exceeding 0.05 L a . Yet the current wording of LCO 3.6.1.1 would provide for only 1 hour to restore the operable status prior to requiring a plant shutdown. The proposed action statement "c.2" requires that one door in the affected air lock be verified to be closed within one hour. This time period is consistent with the required actions of LCO' > 3.6.1.1, which requires that containment integrity be. restored , within 1 hour. The remaining actions of proposed action statement "c.2" are the same as those which currently exist in action statement "b." SR 4.6.1.3.a would be modified by applying the existing note, pertaining to Specification 4.0.2, to the 72 hour test interval for the air lock door seal. The application of this note to the 72 hour surveillance is consistent with how it is currently applied to the 6 month surveillance test required by SR 4.6.1.3.b.1. Since 10 CFR 50, Appendix J, requires the 72 hour frequency for door seal testing, specification 4.0.2 cannot be applied to the 72 hour frequency. Also, the modification to the statement on quantifying total air lock leakage will allow door seal leakage to be quantified. The leakage limit of 0.0005 L a is based on air lock testing experience and leakage limits we feel must be maintained in order to ensure containment internal pressure limits continue to be met in accordance with LCO 3.6.1.4. The proposed statement on quantifying door seal-leakage would contain a new footnote (8). This footnote states that an - inoperable air lock door does not invalidate .the previous. successful performance of. the overall air lock leakage test.

     ~This is reasonable since either air __ lock door is capable of providing a fission product barrier in the event of a design basis accident (DBA).

SR 4.6.1.3.b would be modified. to actually state the leakage limit of less than or equal to 0.05 L. a This change is necessary since the proposed LCO wording would no longer state the leakage limits. SR 4.6.1.3.b would also be modified by the addition of a new footnote (9). This footnote requires that the results of the overall air lock leakage test be evaluated against the acceptance criteria of LCO 3.6.1.2. This action will ensure B-7 ;

l ATTACHMENT B, continued ! Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 8 that air lock leakage is properly accounted for in determining the combined containment leakage rate. SR 4.6.1.3.b.2 would be modified by the addition of the- words " Prior to establishing containment integrity when." This change is necessary to more accurately reflect the wording contained in our exemption to Appendix J. For BVPS Unit 2 only, the footnote pertaining to the exemption to Appendix J would be modified to reflect that the exemption is stated in the operating license. This change will clarify where the exemption is stated. The proposed addition of SR 4.6.1.3.b.3 will ensure that i following maintenance on the outer personnel air lock, which may result in a decrease in closure force on any part of thel door sealing surface, the overall air lock leakage rate is. verified. Due to the unique design of the outer personnel air lock door, where containment DBA pressure is attempting to overcome the door sealing forces, an additional surveillance requirement- is > necessary to demonstrate the continued ability of this door to provide a leak tight barrier, during a DBA, following specific maintenance activities. For both emergency air lock doors and the inner personnel air lock door, containment DBA pressure tends to improve the door sealing capability by applying a force which is supplemental.to the door sealing forces. Performance of the presently required SR 4.6.1.3.a following door opening for such activities as door + maintenance or containment entry and exit, is sufficient to demonstrate the ability of these doors to provide a leak tight ' barrier during a DBA. The sealing force, which is applied to o-rings, is developed by the rotation of wedges against the door's surface. This action forces the. door to compress the o-rings which are located on the air lock barrel. When SR 4.6.1.3.a is performed, the area between. the two concentric o-rings is pressurized and a leak rate of the two o-rings and ; sealing surface is determined. This test pressure. applies an opposing force to the breech ring closure force. Since the ^ containment pressure developed during a DBA applies a closing force which is supplemental to the breech ring force, the net l result would be to improve the door sealing capability of these doors over that which exists during the performance of SR , 4.6.1.3.a. For this reason, performance of SR 4.6.1.3.b, which applies a force which opposes the breech ring force, is not necessary following certain air lock door maintenance. SR 4.6.1.3.a sufficiently demonstrates the ability of these air-lock' doors to provide a leak tight barrier following maintenance affecting the door sealing surface. , Performance of SR 4.6.1.3.a on the outer personnel air lock applies an opposing force to the breech ring closure force in the same manner as previously described for the other air lock doors. However, for the outer personnel air door, the containment pressure developed during a DBA applies an opening force which is opposing the breech ring closure force. B-8 ,

i i ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 l Page 9 : Therefore, upon completion of certain maintenance activities, continued outer door leak tightness during a DBA cannot be assured by performance of SR 4.6.1.3.a alone. Maintenance which may resalt in a decrease in closure force on any part of the door i sealing surface (i.e., decreasing 'of breech ring travel), will require performance of SR 4.6.1.3.b.3. The performance of this surveillance is necessary to ensure that containment DBA pressure applied against the outer door will not result.in the unseating of the air lock door by overcoming of the breech ring closure forces to the point where the leakage becomes excessive. Since ' SR 4.6.1.3.b.3 duplicates DBA forces on.the outer personnel air lock door and also measures the air lock leakage rate, performance of this surveillance requirement demonstrates the continued ability of the outer personnel air lock door to provide a leak tight barrier, during a DBA, .following specific maintenance activities.

The proposed deletion of SR 4.6.1.3.c.2, pertaining to the testing of the emergency air lock shaft seals, will not alter the ;

testing requirements for the emergency air lock. The shaft seals on the emergency air lock will continue to be tested on a 24 month frequency as required by 10 CFR 50, Appendix J. In addition, at least one side of each of the shaft. seals is pressurized to at least P a each time the overall 6 month air lock test is conducted. If the shaft seals were to exhibit. leakage, the overall air lock test would detect and measure.this leakage. The personnel air lock also contains shaft scals on each of the mechanical penetrations for the 18 inch' diameter- ' emergency escape hatch operating mechanisms. There is not a specific technical specification surveillance requirement for these penetrations. The shaft seals on the personnel air lock are Type B leak tested at least once per 24 months under our' Appendix J leak testing program. Therefore, elimination of SR 4.6.1.3.c.2 will not reduce the testing requirements on the emergency air lock and will make the stated technical specification surveillance requirements consistent for the emergency air lock and the personnel air lock. The Bases for LCO 3.6.1.3 would be expanded to contain. additional information pertaining to the specific requirements of this LCO. The proposed changes to the Bases are. consistent with NUREG 1431 and will provide the plant operators with more.information to assist them in understanding the bases for each of the items contained in this specification. D. DEVIATIONS FROM NUREG 1431 TITLED " STANDARD TECHNICAL SPECIFICATIONS FOR WESTINGHOUSE PLANTS." The following is a discussion on why certain aspects of this proposed change do not reflect the wording contained in NUREG 1431. B-9

 -ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1              ,

Page 10 To reflect the wording contained in NUREG 1431 for LCO 3.6.1, titled "Containmerat, " it would be necessary to re-write at'least four LCOs. NUREG 1431 does not contain any reference to the words " Containment Integrity." To remove this wording from our technical specifications would require at least four LCO revisions and many plant procedural changes. Therefore, we have elected to not revise our LCO 3.6.1.1 to reflect NUREG 1431 at 1 this time. The wording contained in LCO 3.6.2 titled " Containment' Air Locks" in NUREG 1431 is reflected in the proposed changes to our ; containment air lock specification with the following l exceptions: Note (1) contained under " Required Actions".was not ! incorporated into our specification. Action statements "a" and "b" reflect specific conditions that the operator is trained to understand and correct within the allowable time. When two air l; lock doors in the same air lock are inoperable, the operators are trained to apply the correct action statement which, in this ; case, is action "c"; no other action statements apply. 1 Therefore, since we feel this note does not enhance this LCO, it was not added to the proposed wording. The bracketed portion of l Note (2) contained under " Required Action" was not included since i entry and exit via our emergency air lock involves personnel i safety and ALARA concerns. Therefore, we do not want to limit: ; access to containment, for the 7 day period, through only the i i emergency air lock when the personnel air lock is locked closed. l Our SR 4.6.1.3 contains details on the requirements of Appendix J testing. We have elected to retain these details so that the i plant operators have the requisite 10 CFR 50 Appendix J details available within the SR each time they are performing air lock operability testing. In addition, the installed leakage detection system, used to test the door o-ring seals, cannot ! quantify door seal. leakage. This system can-only be used to ; verify that no seal leakage is present. Therefore, the present ! wording in SR 4.6.1.3 needs to be retained. If door seal leakage needs to be quantified, special test equipment will be used to accomplish this task. SR 3.6.2.2 in NUREG 1431 states that the verification of the door interlock operability is to be performed on a 184 day frequency. ] Due to the subatmospheric design of our containment, performing j t this verification during plant operation would pose a substantial ; safety risk to plant personnel. Therefore, the 18 month j frequency was retained in our proposed wording. E. SAFETY ANALYSIS The revisions to Definition 1.8.3 and SR 4.6.1.1.b will continue to ensure that containment integrity is maintained or action is taken to place the plant in a safe condition. Compliance with requirements of Specification 3.6.1.3 will ensure at least one B-10 l i 1

ATTACHMENT B, continued-Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 11 ; i operable door is maintained or, as stated in action statement ;

       "c,"  at least one door is maintained closed and an immediate evaluation       of   the     combined   containment   leakage rate is initiated.        If containment integrity cannot be maintained due to           ,

air lock leakage resulting in exceeding the combined coroainment

leakage rate, the action statement of LCO 3.6.1.1 will as entered ,, which will result in correcting the leakage condition or a plant shutdown within 36 hours. General Note (3) reflects this course

of action. The addition of Definition 1.8.5 (to BVPS Unit No. 1 only) will ensure that the sealing mechanism associated with each penetration is operable and .therefore capable of providing a i fission product barrier to prevent a release to the environment.

The new SR 4.6.1.1.c will ensure that any penetration, subject to Type B leak testing, except the containment air locks, will be retested if opened, and the new leakage added to the combined containment leakage rate. This action will ensure that the : containment leakage rate remains at a value which is less than that assumed in our offsite dose calculations during a DBA. l The proposed revisions to LCO 3.6.1.3 will continue to ensure that each containment air lock will perform its safety function as part of the containment pressure boundary to limit offsite radiation exposures resulting from a DBA. The structural integrity and leak tightness will not be changed as a result cf this proposed revision. The addition of the wording "in one or , more containment air locks" is administrative in nature and does not affect plant safety. The addition of the general Note (1) ; and footnote (4) to allow entry and exit through the inoperable ; air lock door will not siginificantly reduce the level of plant i safety. During the period of time when the operable air lock door is open, for entry or exit, the renaining inoperable door i may not prov3de the degree of leak tightness as required by ' technical specifications. Due to the subatmospheric design of BVPS containment building (s), the inoperable air lock door must , be closed and in-leakage limited in order to allow the operable door to be opened. A differential pressure of approximately 5 psid exists between the containment and outside plant areas. Also, the design of the inner door is such that the containment. ; pressure resulting from a DBA will tend to improve the door leak l tightness during the period of time when an inner air lock door is inoperable due to leakage past the seals and the outer door is open. The probability for an event requiring containment integrity occurring during the limited time when.at least one operable door is not closed is sufficiently low to justify ; limited access for short durations when required. Therefore, j based on the above, the addition of these footnotes will not .l significantly affect the ability of the air lock to perform its l intended function. l The addition of proposed action statement "b" will ensure that at least one operable door is maintained closed should the air lock interlock mechanism be inoperable. This action compensates for i B-11 j i j .m_

t ATTACHMENT B, continued j Proposed Technical Specification Change Nos. 199 and 66, Revision 1 , Page 12 , the interlock mechanism being inoperable by precluding any ! situation where the interlock would be required to operate. ; Administrative controls are substituted for the design feature of ! the interlock. Therefore, the compensatory' measures.provided by the proposed action statement "b" will continue to ensure that containment integrity is being maintained while the air lock is , being used. With one operable door maintained closed, the- ! containment will function, as assumed, to limit.the release of ; radioactive materials under the maximum post accident containment pressure. The proposed revision to SR 4.6.1.3.a, to allow door seal leakage . to be quantified, will allow for minor door seal leakage. The , current SR 4.6.1.3.a requires that the door seals exhibit-zero leakage to demonstrate their operability. By adding the ability to quantify door seal leakage, the door seals can be considered - operable with a measured leak. rate of 0.0005 L . This leak rate is sufficiently small to ensure the continued ability of the door seals to restrict the release of fission products to the environment. The proposed addition of footnote (8), which states an inoparable door does not invalidate the previous successful performance of the overall air lock leakage testing does not affect-the ability of the air lock to restrict the release of fission products to the environment. The remaining operable door is still capable of performing this function. The overall air lock leakage test takes into account the leakage of both air lock doors due.to the manner in which the test is_ conducted. If the remaining operable air lock door has had maintenance performed on it which could affect its sealing capability, since the last performance of the i overall air lock leakage test, proper post-maintenance testing, t such as the testing required by the proposed SR 4.6.1.3.b.3, will continue to ensure that it will restrict the release of fission products to the environment. Therefore, the leakage rate of the, air lock with one door inoperable is bounded by the previous overall test conducted with both doors operable. The proposed addition of the words " Prior to establishing containment integrity when" does not affect the ability of the- . air lock to perform its intended function. This change is a i clarification of our current exemption to 10 CFR~50 Appendix J. l Appendix J requires air lock testing prior to plant operation ; when the air lock has been opened during periods when containment , integrity is _not required. We are exempted from this testing if ! no maintenance has been performed on the air lock which~could i affect its sealing capability. j The remaining proposed changes are administrative in nature and do not affect the ability of the containment air lock (s) to ! restrict the release of fission products to the environment. ! l i B-12 i

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66,-Revision 1 7 Page.13 Therefore, this change is considered safe based on 1) the continued ability of the containment air locks to provide a barrier to the release of radioactive materials from a DBA, under maximum post accident containment pressure, thereby ensuring the limits established by 10 CFR 100 are not exceeded, or 2) the low probability of a DBA occurring during momentary opening of the remaining operable air lock door to allow containment entry and exit. F. NO SIGNIFICANT HAZARDS EVALUATION r Thre no significant hazard considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below: The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment- 1 to an operating license for a facility licensed under ; paragraph 50.21(b) or paragraph 50.22 or for a testing , facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: (1) Involve a significant increase in the probability or ; consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of j accident from any accident previously evaluated; or ; t (3) Involve a significant reduction in a margin of' safety. The following evaluation is provided for the no significant hazards consideration standards. ,

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The probability of occurrence of a previously evaluated' accident is not increased because the containment air locks do not effect the initiation of any design basis accident. The consequences of an accident are also not significantly , increased because- the proposed revisions to the- action ' statements will continue to ensure that at least one door in each air lock is maintained closed. A single door in each air lock is capable of withstanding a pressure in excess of the maximum expected pressure following a DBA. The structural integrity and leak tightness of the containment will not be changed by. this proposed revision. For the brief period of time that the operable air lock door is open and the inoperable door is providing thc single concainment barrier, the consequences of accident may be increased. B-13

ATTACHMENT B, continued . Proposed Technical Specification Change Nos. 199 and 66, Revision 1 ! Page 14 i However, the probability of an event occurring requiring . containment integrity is sufficiently remote to justify limited access when required. Therefore, based on the continued ability of the containment ) air locks to provide a barrier to limit leakage from

containment during a DBA, this . proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

Air lock operation does not interface with._the reactor coolant pressure boundary or any other mechanical or electrical controls which could impact the operations of the reactor or its direct support systems. Containment air locks are designed for the purpose of containment entry and exit. During this operation, the air

lock maintains containment integrity by providing at 1 east one door which is capable of providing a leak tight barrier during a DBA. The proposed changes will continue to ensure that air lock operation is performed as assumed in the original design of the plant. During the period when the operable door is open and the other door inoperable, at least one door-is being; maintained closed as designed. This condition is' ensured due to the subatmospheric conditions that exists during plant operation. The operable air lock door can not be safely opened unless the inoperable door is closed due to the approximately 5 psi pressure differential that exists. The operable air lock door would only be opened long enough to allow personnel to enter the air: lock. Therefore, this proposed change does not create. the i possibility of a new or different kind of accident from any-accident previously evaluated.

3. Does the change involve a significant reduction in a margin of safety?

The applicable margin of safety consists of maintaining:the primary containment leak rates within the assumptions of the DBA analysis. These leak rates are maintained provided at least one operable air lock door remains closed during the event. The proposed revisions will continue to ensure that at least one air lock door is maintained closed. During the brief period of time that an operable air lock door is open and-l B-14

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 15 the inoperable -door is providing the . single containment barrier, the margin of safety is decreased. The inoperable , door may not limit containment leak rates' within the ! assumptions of the-~DBA analysis._ However, the probability of an event requiring the inoperable air. lock door to limit. containment leakage occurring during this time' period is sufficiently low and_the overall margin of safety would not be decreased by a significant amount. The proposed increase in allowable door seal leakage will not affect the.overall ability of the containment air locks to restrict the' release of fission products to the environment. The overall air lock leakage limit of less than or equal to .05 La remain

unchanged. The amount of leakage which the air lock (s) are perr.itted to contribute to the combined containmr.nt' leakage-limit of 0.60 La remain unchanged. Therefore, the margin of safety due to increasing the door seal leakage limit remains unchanged. Therefore, this proposed change does not involve' a significant reduction in a margin of safety. G. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that ' the activities associated with this license amendment request satisfies the no significant lazards consideration standards-of 10 CFR 50.92(c) and, accordir. gly, a no significant hazards consideration finding is justified. b B-15

1

                                                                            'l ATTACHMENT C-1                            !

l Beaver Valley Power Station, Unit No. 1- ' Proposed Technical Specification Change No. 199, Revision 1 '

      .                 ,                                               ~    ,

I l Applicable Typed Pages l r l I i t

a l E a a i i i

i i i , e 1 L

t i ATTACHMENT TO LICENSE AMENDMENT NO. . . .s'~ FACILITY OPERATING LICENSE NO. DPR-66 ; DOCF:RT NO. 50-334 ! i, Replace the following pages of Appendix A, Technical' Specifications,- with the enclosed pages as indicated. The -revised pages are identified by amendment. number and contain vertical. linos indicating the areas of change. .

                                                                                                          ..a Remove                                        Insert i

XIV XIV i 1-2 1-2 i 3/4 6-1 3/4 6-1 [ 3/4 6-5 3/4 6-5 , 3/4 6-Sa 3/4 6-Sa :) 3/4 6-5b 3/4 6-Sc i B 3/4 6-1 B 3/4 6-1 ; B 3/4 6-2 B 3/4 6-2 . B 3/4 6-3 B 3/4 6-3 , B 3/4 6-4 l B 3/4 6-5' t B 3/4 6-6 B 3/4 6-7 , B 3/4 6-8 ! B 3/4 6-9 ; B 3/4 6-10 ! B 3/4'6-11 , i i i l l (Proposed Wording)

t t DPR-66 INDEX ;

                                                                                                               .5
    ~ BASES                                                                                                      ,
                                                                                                          =o     i SECTION                                                                                     PAGE            l 3/4.6   CONTAINMENT SYSTEMS 3/4.6.1        PRIMARY CONTAINMENT 3/4.6.1.1      Containment Integrity .                . . .. . . . . . .                 B 3/4 6-1          ;

3/4.6.1.2 Containment Leakage . . . . . - . . . . . . B'3/4 6-1 d 3/4.6.1.3 Containment Airlocks . . . . . . . . . . B 3/4 6-1 f 3/4.6.1.4 & , 3/4.6.1.5 Internal Pressure and Air Temperature . . B 3/4.6-9 [ 3/4.6.1.6 Containment Structural Integrity . . . . B 3/4 6-9 - 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 & , 3/4.6.2.2 Containment Quench and Recirculation 1 Spray Systems . . . . . . . . . . . . . . B 3/4-6-10 l 3/4.6.2.3 Chemical Addition System . . . . . . . . . B 3/4 6-10 [ i 3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . B 3/4 6-10 l 1 3/4.6.4 COMBUSTIBLE GAS CONTROL . . . . . . . . . B 3/4 6-11 3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM ; 3/4.6.5.1 Steam Jet Air Ejector . . . . . . . . . . B 3/4 6-11 l 3/4.7 PLANT SYSTEMS ! 3/4.7.1 TURBINE CYCLE 3/4.7.1.1 Safety Valves . . . . . . . . . . . . . . B 3/4-7-1 3/4.7.1.2 Auxiliary Feedwater Pumps . . . . . . . . B 3/4 7-2 1 3/4.7.1.3 Primary Plant Demineralized Water . . . . B 3/4 7-2 : 3/4.7.1.4 Activity . . . . . . . . . . . . . . . . B 3/4 7-3 3/4.7.1.5 Main Steam Line Isolation Valves . . . . ? 3/4 7-3 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE , LIMITATION . . . . . . . . . . . . . . . B 3/4 7-4 BEAVER VALLEY - UNIT 1 XIV Amendment No.

                                  .(Proposed Wording)                                                              j

i DPR-66 ; l DEFINITIONS i FEPORTABLE EVENT ;

      .1.7      A REPORTABLE EVENT shall be any of those conditions specified          .

in Section 50.73.to 10 CFR Part 50. l l CONTAINMENT INTEGRITY 4 1.8 CONTAINMENT INTEGRITY shall exist when: 1.8.1 All penetrations required to be closed during accident : conditions are either:

a. Capable of being closed by an OPERABLE ,

containment automatic isolation valve system, or j

b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except as provided in Table 3.6-1 of Specification 3.6.3.1. j 1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each air lock is in compliance with the requirements of Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and I 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows, or O-rings) is OPERABLE.

CHANNEL CALIBRATION

                                                                                     -l 1.9        A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range            j and accuracy to known values of the parameter which the channel.                 '

monitors. The CHANNEL CALIBRATION shall encompass the entire , channel including the sensor and alarm.and/or trip functions, and 1 shall include the CHANNEL. FUNCTIONAL TEST. The CHANNEL CALIBRATION -) may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated. ; CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative' assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication.and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter. BEAVER VALLEY - UNIT 1 1-2 Amendment No. (Proposed Wording)

DPR-66' 3/4.6 CONTAINMENT SYSTEMS 3 / 4 ~. 6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY . I LIMITING CONDITION FOR OPERATION ; 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained. l i APPLICABILITY: MODES 1, 2, 3 and 4. { ACTION: l Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 36 hours. j SURVEILLANCE REQUIREMENTS ! 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated: ,

a. At least once per 31 days by verifying that:

1. All penetrations (1) not capable of being closed by I t

OPERABLE containment automatic isolation valves and required to be closed during accident conditions are i closed by valves, blind flanges, or deactivated ; automatic valves secured in their positions, except as provided in Table 3.6-1 of Specification 3.6.3.1. j

2. Alt guipment hatches are' closed and sealed.

b. By verifying that each containment air lock is in compliance with the requirements of Specification 3.6.1.3._ l i

c. After each closing of each penetration subject to Type B i testing, except the containment air locks, .if opened following a Type A or B test, by leak rate testing the seal '

with gas at a pressure not less than P a (40.0 psig), and verifying that when the measured leakage rate for these j seals is added to the leakage rates determined pursuant to ! Specification 4.6.1.2.d for all other Type B and C , penetrations, the combined leakage rate is less than ; 0.60 L a* ! (1) Except valves, blind flanges, and deactivated automatic valves I i which are located inside the containment and are locked, sealed, or otherwise secured in the closed position. These penetrations l shall be verified closed during each COLD SHUTDOWN except that ; such verification need not be performed more often than once per ! 92 days. l BEAVER VALLEY - UNIT 1 3/4 6-1 Amendment No. I (Proposed Wording) i 1 l

 ~       .      ..                      . .                 _. -.       .

^ DPR-66 CONTAINMENT SYSTEMS i l I C9NTAINMENT AIR LOCKS

                                                                                                    'i LIMITING CONDITION FOR OPERATION                                                                     i i

3.6.1.3 Two containment air locks shall be OPERABLE: l l t APPLICABILITY: MODES 1, 2, 3 and 4. , ACTION:

   - - - - - - - - - - - - - GENERAL NOTES - - - - - - - - - - - - - -                                 l

1. Entry and exit is permissible to perform repairs on the '

affected air lock components.

2. Separate ACTION statement entry is allowed for each air ;

lock. ;

3. Enter the ACTION of LCO 3.6.1.1, when air lock leakage [

results in exceeding the combined containment leakage rate. i

a. With one containment air door inoperable in one or morecontainmentairlocks:(4 pock

m. Verify the OPERABLE door is closed in the affected air !'

lock within 1 hour, and l J

2. Lock the OPERABLE door closed in the affected air lock !

within 24 hours, and {

.i

3. Verify the OPERABLE door is locked clo g in the f affected air lock at least once per 31 days. ;

4. Otherwise, be in at least HOT STANDBY within the next ;

6 hours and in COLD SHUTDOWN within the following 30 hours. l (4) Entry and exit is permissible for 7 days under administrative controls to perform activities not related to the repair of affected air lock components. (5) Air lock doors in high radiation areas may be verified locked , closed by administrative means. i BEAVER VALLEY - UNIT 1 3/4 6-5 Amendment No. (Proposed Wording) 8

I DPR-66 r CONTAINMENT SYSTEMS l

LIMITING CONDITION FOR OPERATION ACTION: (Continued) !

b. With the containment air lock- interlock inoperable in one or more containment air locks:(6) mechanism ,

1. Verify an OPERABLE door is closed in the affected air lock within 1 hour, and ;

2. Lock an OPERABLE door closed in the affected air lock within 24 hours, and ,

3. Verify- an OPERABLE door is locked clos 9 in the -

affectedairlockatleastonceper31 days.Lg)

4. Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

I f

c. With one or more containment air locks inoperable, except as the result of an inoperable air lock door and/or inoperable interlock mechanism:

1. Immediately initiate action to evaluate the combined i containment leakage rate per LCO 3.6.1.2, and !

2. Verify a door is closed in the affected air lock, !

within 1 hour, and

3. Restore the air lock to OPERABLE status within 24 ,

hours.

4. Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

i i (5) Air lock doors in high radiation areas may be verified locked-closed by administrative means. i (6) Entry and exit of containment is permissible under control of a dedicated individual. l BEAVER VALLEY - UNIT 1 3/4 6-Sa _ Amendment No. (Proposed Wording) I l

l l DPR-66 CONTAINMENT SYSTEMS l i SURVEILLANCE REQUIREMENTS i 4.6.1.3 Each containment air lock shall,be demonstrated OPERABLE: I

a. Within 72 hoursI7) following each containment entry, I except when the air entries, lockisbeingusedform}{iple then at least once per 72 hours, by i verifying no detectable seal leakage when the gap between the door seals is pressurized for at least:2 l minutes to:

1. Personnel air lock greater than or equal to I ;

40.0 psig

2. Emergency air lock greater than or equal

to l- 1 10.0 psig or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less than or equal- 1 to 0.0005 L a at P a (40.0 psig) for the personnel air lock and 0.0005 L a at 10.C psig for the i emergency air lock. {

b. By conducting overall air lock leakage tests,(9) at' I ,

not less than P (40.0 psig), and verifying the 1 overall air lock Seakage rate is less than or equal to j ' O.05 L a at P a (40.0 psig): l

1. At least once per 6 months,(7) and 3

2. Prior to establishing CONTAINMENT-INTEGRITY when !

maintenance has been performed on the air lock that could the air lock sealing capability,(10) affect and l { (7) The provisions of Specification 4.0.2 are not applicable. , (8) An inoperable air lock door does not invalidate the ' previous successful performance of the ~ overall air lock

leakage test. ;

(9) Results shall be evaluated against the acceptance criteria ; of LCO 3.6.1.2. (10) Exemption to Appendix J of 10 CFR 50, dated November 19, ! 1984. r i BEAVER VALLEY - UNIT 1 3/4 6-5b Amendment No. l , (Proposed Wording) -l

P DPR-66 ; CONTAINMENT SYSTEMS- l SURVEILLANCE REOUIREMENTS (Continued) , maintenance ~ performed on the outer

3. Following personnel air lock door which may result in a- I decrease in closure force on any part of the door sealing surface.

c. At. least once per 18 months during shutdown by verifying:

1. Only one door in each air lock can be opened at a time. .,

L i f i I BEAVER VALLEY - UNIT 1 3/4 6-Sc Amendment'No. l (Proposed Wording) I

DPR-66 l -3/4.6 CONTAINMENT SYSTEMS l R BASES

i 3/4.6.1 PRIMARY CONTAINMENT i 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be ,

restricted to those leakage paths and associated leak ~ rates assumed. ' in the accident analyses. This restriction, in conjunction with the !' leakage rate limitation, will limit the site boundary radiation dosas to within the limits of 10 CFR 100 during accident conditions. i 3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total. , containment leakage volume will not exceed the value assumed in the ! accident analyses at the peak accident pressure, P. As an added conservatism, the measured overall integrated le$kage rate is ; further limited to less than or equal to 0.75 La during performance of the periodic test to account for possible degradation 1 of the containment leakage barriers between leakage tests. ! The surveillance testing for measuring' leakage rates are consistent with the requirements of Appendix "J" of 10 CFR 50. ! l' The exemption to 10 CFR 50 Appendix J.III.D.1(a) allows Type A tests to be conducted on a 40 1 10-month schedule, not in conjunction with any ISI tests. j i 3/4.6.1.3 CONTAINMENT AIR LOCKS , BACKGROUND e Containment air locks form part of the containment pressure boundary ; and provide a means for personnel access during all MODES of operation. Each air lock is nominally a right circular cylinder, with a door at i each end. The doors are interlocked to prevent simultaneous. opening. During periods when containment is not required to be _ OPERABLE, the door interlock mechanism may be disabled, allowing l' both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. The emergency air lock, f which is located in the equipment hatch opening, is normally removed 'l from the containment building and stored during a refueling outage. Each air lock door has been designed and tested to certify its j ability to withstand a pressure in excess of the' maximum expected ! pressure following a Design Basis Accident (DBA) in containment. As j i i BEAVER VALLEY - UNIT 1 B 3/4 6-1 Amendment No. ! (Proposed Wording) l

DPR-66 , 3/4.6 CONTAINMENT SYSTEMS l BASES j 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) BACKGROUNp (Continued) such, closure of a ' single door supports containment OPERABILITY. i Each of the doors contains double o-ring seals and local leakage rate testing capability to ensure pressure integrity. DBA conditions which increase containment pressure will result in , increased sealing forces on the personnel air lock inner door and both doors on the emergency air lock. The outer door on the ; personnel air lock is periodically tested in a manner where the containment DBA pressure is attempting to overcome the door sealing i forces. The containment air locks form part of the containment pressure boundary. As su"h, air lock integrity and- leak tightness is j essential for maintaining the containment leakage rate within limits i in the event of a DBA. Not maintaining air lock integrity or leak ! tightness may result in a leakage rate in excess of that assumed in I the unit safety analyses. SR 4.6.1.2 leakage rate requirements ; cc sly with 10 CFR- 50, Appendix J, as modified by approved ; exemptions. APPLICABLE SAFETY ANALYSES The DBAs that result in a release of radioactive material within containment are a loss of coolant accident and a rod ejection accident. In the analysis of each of these accidents, it is assumed ! that containment is OPERABLE such that release of fission products. to the environment is controlled by the rate .of containment leakage. The containment was (Jesigned with an allowable leakage , rate of 0.1 percent of containment air weight per day. This leakage ' rate is defined in 10 CFR 50, Appendix J, as L a = 0.1 percent of containment air weight per day, the maximum allowable containment leakage rate at the calculated peak containment internal pressure P = 40.0 psig following a DBA. This allowable leakage rate forms j the basis for the acceptance criteria imposed on the SRs associated J with the air locks. BEAVER VALLEY - UNIT 1 B 3/4 6-2 Amendment No. (Proposed Wording)

t DPR-66

 .3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3     CONTAINMENT AIR LOCKS (Continued)

LCD Each containment air lock forms part of the containment pressure boundary. As part of containment, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness , are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to'be' considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. . Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into and exit from containment, j APPLICABILITY In Modes 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability _and t consequences of these events are reduced due to the pressure and- , temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of , radioactive material from containment. The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9.4,

  " Containment Building Penetrations."

ACTIONS The ACTIONS are modified by a General Note (1) that allows entry and exit to perform repairs on the affected air lock component. If the outer door is inoperable, then it may be easily accessed to repair. e If the inner door is the one that is inoperable, however, then a j short time exists when the containment boundary may not be 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

BEAVER VALLEY - UNIT 1 B 3/4 6-3 Amendment No. (Proposed Wording)

-i

                                                                                      .i DPR-66                     _

f 3/4.6 CONTAINMENT SYSTEMS l

BASES ,

3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) j ACTIONS (Continued)

l in which the OPERABLE door is expected to be open. At no time should the OPERABLE door be opened if it cannot be demonstrated that the inoperable door is sufficiently closed / latched such that it i could inadvertently open while the OPERABLE door is opened. After !

each entry and exit, the OPERABLE' door must be immediately closed. If ALARA conditions permit and personnel safety can be_ assured, , entry and exit should be via an OPERABLE air lock. General Note (2) has been added to provide clarification that, for this LCO, separate Action statement entry is allowed for each air l lock. In the event the air lock leakage results in exceeding the combined containment leakage rate, General Note (3) directs entry into the Required Action of LCO 3.6.1.1. !

a. With one air lock door in one or more. containment air locks inoperable, the OPERABLE door must be verified closed .l (Required Action a.1) in each affected ' containment air .

lock. This ensures that a leak tight containment barrier 1 is maintained by the use: of an OPERABLE air lock door. ' This action must be completed within 1 _ hour. This specified time period is consistent with- the Required Action of LCO 3.6.1.1, which requires CONTAINMENT INTEGRITY' , to be restored wi. thin 1 hour. In addition, the affected air lock -penetration must.be isolated by locking closed (Required Action a.2) the OPERABLE air lock door within the 24 hour Completion Time. The 24 hour Completion Time is reasonable for locking the OPERABLE air lock door, considering the OPERABLE door of the affected air lock is being maintained closed. This action places additional positive controls on the use of the air lock when one air lock door is inoperable. l Required Action a has been modified by a Note. Note ' ~( 4 ) allows use of the air lock for entry and exit for 7 days under administrative controls. Containment entry may-be required to perform non-routine Technical -Specification (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. An example of such an activity would be the isolation of a containment penetration: by' at least one operable valve, and the subsequent repair and BEAVER VALLEY - UNIT 1 B 3/4 6-4 Amendment No. l (Proposed Wording)

DPR-66 3/4.6 CONTAINMENT SYSTEMS ; BASES l t 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) ACTIONS (Continued) - post-maintenance technical specification surveillance l testing on the inoperable valve. In addition, containment i entry may be required to perform repairs on vital plant equipment which, if not repaired, could lead to a plant l transient or reactor trip. This Note is not intended-to preclude performing other activities (i.e., non-TS-required activities or repair of non-vital plant equipment)' if the , containment is entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance F 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. ; 5 Required Action a.3 verifies that an air lock with an l inoperable door has been isolated by the use of a locked and closed OPERABLE air lock door. This ensures that-an acceptable containment leakage boundary is maintained. The - Completion Time of once per 31 days is based on engineering , judgment and is considered adequate in view of the low : likelihood of a locked door being mispositioned. Required' Action a.3 is modified by a Note (5) that applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed by use of. administrative , means. Allowing verification by administrative-means is i considered acceptable, since access to these areas' is-typically restricted. Therefore, it is unlikely that a door would become misaligned once it has been verified to be in the proper position. ,

h. With an air lock interlock mechanism inoperable in_one or :

more air locks, the Required Actions and associated ' Completion Times are consistent with those specified in ! Required Action a. ! The Required Actions have been modified by two Notes. Note 3 (6) allows entry into and exit from containment 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). Note l (5) applies to air lock doors located in high radiation areas and allows these doors to be verified locked closed , by use of administrative means. Allowing verification by administrative means is considered acceptable, since access BEAVER VALLEY - UNIT 1 B 3/4 6-5 Amendment No. l (Proposed Wording)

DPR-66 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) A.CTIONS (Continued) to these areas is typically restricted. Therefore, it is unlikely that a door would become misaligned once it has been verified to be in the proper position.

c. With one or more air locks inoperable for reasons other.

than those described in Required Actions a or b, Required Action c.1 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 limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour (per LCO 3.6.1.1) 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 combined containment leakage rate can still be within limits. Required .cion c.2 requires that one door in the affected containmcat air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the Required Actions of LCO 3.6.1.1, which requires " at CONTAINMENT INTEGRITY be restored within 1 hour. Additionally, Required Action c.3 requires that the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one door is maintained closed in each affected air lock. For all Required Actions, if the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within the following 30 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. BEAVER VALLEY - UNIT 1 B 3/4 6-6 Amendment No. l (Proposed Wording)

 -DPR-66 3/4.6 CONTAINMENT SYSTEMS i

BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) SURVEILLANCE REOUIREMENTS (SR) Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of 10 CFR 50, Appendix J, as modified by approved exemptions. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage

tests). The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by Appendix J, as modified by approved exemptions. Note (10) reflects the current " approved exemption from Appendix J. Thus, SR 4.0.2 (which allows Frequency extensions) does not apply as stated in Note (7). Testing of the personnel air lock door seals may be accomplished with the air lock pressure equalized with containment or with atmospheric pressure. Each configuration applies P , as a minimum, across the sealing surfaces demonstrating the ability to function as designed. As long as the , testing conducted is equivalent or more conservative than what might exist for accident conditions, the air lock doors will be able to perform their design function. Performance of maintenance activities which affect air lock sealing capability, such as the replacement of the o-ring door seals and/or breach ring travel adjustment, will require performance of the appropriate surveillance requirements such as SR 4.6.1.3.a as a 3 minimum. The performance of SR 4.6.1.3.b will depend on the air lock components which are affected by the maintenance. Replacement of o-rings and/or breech ring travel adjustment on the inner personnel air lock door, for example, normally will not require the performance of SR 4.6.1.3.b as a post maintenance test. Testing per SR 4.6.1.3.a is sufficient to demonstrate post accident leak tightness of the inner air lock door. The sealing force, which is applied to o-rings, is developed by the rotation of tapered wedges against the door's outer surface. This action forces the door to compress the o-rings which are located on the air lock barrel. When , SR 4.6.1.3.a is performed, the area between the two concentric o-rings is pressurized to at least P a and a leak rate of the two 0-rings and sealing surface is determined. This test pressure applies an opposing force to the breech ring-closure force. Since the containment pressure developed during a DBA applies a closing force which is supplemental to the breech ring force, the net result would be to improve the door sealing capability of the inner personnel air lock door over that which exists during the performance of SR 4.6.1.3.a. For this reason, performance of SR BEAVER VALLEY - UNIT 1 B 3/4 6-7 Amendment No. l (Proposed Wording) l

l l DPR-66 j 3/4.6 CONTAINMENT SYSTEMS BASES i 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) SURVEILLANCE REOUIREMENTS (SR) (Continued) 4.6.1.3.b, which applies a force which opposes the breech ring force, is not necessary following certain inner air lock door maintenance. SR 4.6.1.3.a sufficiently demonstrates the ability of the inner air lock door to provide a leak tight barrier following maintenance affecting the door sealing surface. Replacement of the o-rings on the outer personnel air lock door, which results in decreasing the breech ring closure force, will require performance of SR 4.6.1.3.b in addition to SR 4.6.1.3.a which is required due to the door being opened. This surveillance is required because containment DBA pressure tends to overcome the outer personnel air lock door sealing forces. Performance of SR 4.6.1.3.a on the outer personnel air lock applies an opposing force to the breech ring closure force in the same manner as previously described for the inner personnel air lock door. However, for the outer personnel air door, the containment pressure developed during a DBA applies an opening force which is opposing the breech ring closure force. Therefore, upon completion of certain maintenance activities, continued outer door leak tightness during a DBA cannot be assured by performance of SR 4.6.1.3.a alone. Maintenance which may result in a decrease in closure force on any part of the door sealing surface, (decreasing of breech ring travel for example), will require performance of SR 4.6.1.3.b. The performance of this surveillance is necessary to ensure that containment DBA pressure applied against the outer door will not result in the unseating of the air lock door by overcoming of the breech ring closure forces to-the point where the leakage becomes excessive. Since SR 4.6.1.3.b duplicates DBA forces on the outer personnel air lock door and also measures the air lock leakage rate, performance of this surveillance requirement demonstrates the continued ability of the outer personnel air lock door to provide a leak tight barrier, during a DBA, following specific maintenance activities. The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY and personnel safety, considering the subatmospheric design, while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. BEAVER VALLEY - UNIT 1 B 3/4 6-8 Amendment No. l (Proposed Wording) b

 -DPR-66 3/4.6 CONTAINMENT SYSTEMS                                                       l BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued)

SURVEILLANCE REOUIREMENTS (SR) (Continuedl The SR has been modified by two additional Notes. Note (8) states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This' , is considered reasonable since either air-lock door is capable of l providing a fission product barrier in the event of a DBA. Note (9) has been added to this SR requiring the results to be evaluated against the acceptance criteria of LCO 3.6.1.2. This ensures that ; air lock leakage is proparly accounted for in determining the i combined containment leakage rate. 3/4.6.1.4 and 3/4.6.1.5 INTERNAL PRESSURE AND AIR TEMPERATURE The limitations on containment internal pressure and average air temperature as a function of river water temperature ensure that 1)- the containment structure is prevented from exceeding its-design negative pressure of 8.0 psia, 2) the containment peak pressure does , not exceed the design pressure of 45 psig during LOCA conditions, and 3) the containment pressure is returned to subatmospheric conditions following a LOCA. ! The containment internal pressure and temperature limits shown as a : function of river water temperature describe the operational ! envelope that will 1) limit the containment peak pressure to less than its design value- of 45 psig and 2) ensure the containment j internal pressure returns subatmospheric within 60 minutes following 1 a LOCA. -! The limits on the parameters of Figure 3.6-1 are consistent with the l assumptions of the accident analyses. 1 3/4.6.1.6 CONTAINMENT STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of the containment vessel will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the vessel will withstand the maximum pressure of 40.0 psig in the event of a LOCA. The visual and Type A; I leakage tests are sufficient to demonstrate this capability. I i BEAVER VALLEY - UNIT 1 B 3/4 6-9 Amendment No. l (Proposed Wording)

DPR-66 , 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS , 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT OUENCH AND RECIRCULATION SPRAY SYSTEMS The OPERABILITY of the containment' spray systems ensures that . containment depressurization and subsequent return to subatmospheric pressure will occur in the event of a LOCA. The pressure reduction and resultant termination of containment leakage are consistent with-the assumptions used in the accident analyses. The recirculation spray system consists of four 50 percent capacity subsystems each composed of a spray pump, associated heat exchanger and flow path. Two of the recirculation spray pumps and motors are located outside containment (RS-P-2A and RS-P-2B) and two pumps and motors are located inside containment (RS-P-1A and RS-P-1B). -The flow path from each pump is piped to an individual 180' recirculation spray header inside containment. Train "A" electrical _, power and river water is supplied to the subsystems containing l recirculation spray pumps RS-P-1A and RS-P-2A. Train "B" electrical , power and river water is supplied to the subsystems containing recirculation spray pumps RS-P-1B and RS-P-2B. , 3/4.6.2.3 CHEMICAL ADDITION SYSTEM The OPERABILITY of the chemical addition system ensures that sufficient NaOH is added to the' containment spray'in the event of a-LOCA. The limits on NaOH minimum volume and concentration, ensure ; that 1) the iodine removal efficiency of the spray water is maintained because- of the increase in pH value, and 2) corrosion effects on components within containment are minimized. These assumptions are consistent with the iodine removal efficiency assumed in the accident analyses. 3/4.6.3 CONTAINMENT ISOLATION VALVES 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. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analysis for a LOCA. 1 BEAVER */ ALLEY - UNIT 1 B 3/4 6-10 Amendment No. l > (Proposed Wording)

l l DPR-66 CONTAINMENT SYSTEMS I BASES i 3/4.6.4 COMBUSTIBLE GAS CONTROL l The OPERABILITY of the equipment and systems required for the H detection and control of hydrogen gas ensures that this equipment I will be available to maintain the hydrogen concentration within l 1 containment. below its flammable limit during post-LOCA conditions. Either recombiner unit is capable of controlling the expected y hydrogen generation associated with 1) zirconium-water reactions,

2) radiolytic decomposition of water 3) cerrosion of metals within 1 containment. These hydrogen control systems are consistent with the !

recommendations of Regulatory Guide 1.7, " Control of Combustible Gas i Concentrations in Containment Following a LOCA." 3/4.6.5 SUBATHOSPHERIC PRESSURE CONTROL SYSTEM 3/4.6.5.1 STEAM JET AIR EJECTOR The closure of the manual isolation valves in the suction of the steam jet air ejector ensures that 1) the containment internal pressure may be maintained within its operation limits by the mechanical vacuum pumps and 2) the containment atmosphere is isolated from the outside environment in the event of a LOCA. These valves are required to be closed for containment isolation. . l BEAVER VALLEY - UNIT 1 B 3/4 6-11 Amendment No. l (Proposed Wording)

ATTACHMENT C-2 Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 66, Revision 1 1 Applicable Typed Pages l i l

y . - - i ATTACHMENT TO LICENSE AMENDMENT NO. j FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 l Replace the following pages of Appendix A, Technical Specifications, i with the enclosed pages as indicated. The revised pages- are identified by amendment number and contain vertical lines indicating . the areas of change. ; Remove Insert I I II II XI XI 1-2 1-2 : 1-3 1-3 1-4 1-4 1-5 1-5 ; i 1-6 1-6 1-7 1-7 1-8 1-8 1-9 3/4 6-1 3/4 6-1 3/4 6-4 3/4 6-4 i 3/4 6-5 3/4 6 ---- 3/4 6-Sa ; 3/4 6-Sb ' B 3/4 6-1 B 3/4 6-1 B 3/4 6-2 B 3/4 6-2 . B 3/4 6-3 B 3/4 6-3 B 3/4 6-4 B 3/4 6-5 B 3/4 6-6 B 3/4 6-7 B 3/4 6-8 B 3/4 6-9 B 3/4 6-10 B 3/4 6-11 .' i (Proposed Wording) ,

l. .

    . ~            _

y.. ._ .. ._ _ _ . __ . - . ._ j M i

~)

NPF l!e INDEX~ 1

          ' DEFINITIONS                                                                                                                                 :

i i i

                                                                                                                                                     .t l'             SECTION                                                                                                                       PAGE        l
                                                                                                                                                        ?

1.0 DEFINITIONS ' 1.1 DEFINED TERMS . . . . . . . . .. . . . . . . . . . . . 1 ' 1.2 THERMAL POWER . . . . . . . . . . . . . _ . .. . . .. . .. .1-1 ;j

          -1,3         RATED THERMAL POWER . . . . .- . . . . . . ._ . . . . .. .                                                           1-1         5 a

1.4 OPERATIONAL MODE . . . . . . . . . . . .. . . . . . . . . [1-1_

          '1.5         ACTION   . . . . . . . . . . . . . . . . . . .. . .. .                                                               1-1      -j
                                                                                                                                                      -i 1.6      OPERABLE - OPERABILITY                     . . . . . . . . . . . . . . . .                                           1-1         j j

i .. 1.7 REPORTABLE EVENT . . . . . . . . . . . . . . . . - . . . .1-l' 'I 1.8 CONTAINMENT INTEGRITY . . . . . . . . . . . . . .. . . . '1-1 i 1.9 CHANNEL CALIBRATION . . . . . . . .. . . . . . . .- . . 1-2' l 1 1.10 CHANNEL CHECK < . . . . . . . . . ... . . . . . . . .. .. 1-2 ...

                                                                                                                                                      -i 1.11     CHANNEL FUNCTIONAL TEST                       . . . . .. . . . . - . . . . . . .                                     1-2         ;
                                                                                                                                                     .i CORE ALTERATION                                                                                                      1-2.

1.12 . . . . .. . . . . . . . . .. . . . - . 1.13 SHUTDOWN MARGIN . . . . . . . . . . . . . _ . . . . . . .. 1-3 l j

                .                                                                                                                                    -i 1.14     IDENTIFIED LEAKAGE . ...       -              . . . . _ . . . . . . .. . .. .                                        1    -l l

1.15 UNIDENTIFIED LEAKAGE . . . . . . . . . . . . . . . . . . 1-3 I 1 1.16 PRESSURE BOUNDARY LEAKAGE . . . . .. . . . . . . . . . . 1-3' i 1.17 CONTROLLED LEAKAGE . . . . . . . . . . . . . . .. . . .. 1-3 1 ll

           '1.18       QUADRANT POWER TILT RATIO                         .. . . .. . . . .                     . . . . .                    1-3         i j

1.19 DOSE EQUIVALENT I-131 . . . . . . . . . . . . . . . . 1-4

1.20 STAGGERED TEST BASIS . . . . . . . . . . . . ... . . . .,1-4 ! 1 t 1.21 FREQUENCY NOTATION . . . . . . . . . . . . . .. . . . .- . 1-4: > 1.22 REACTOR TRIP RESPONSE TIME . . . . . . . . . .. . .-. . 1-4 : i j

                                                                                                                                                     .. i i

!, BEAVER VALLEY - UNIT ~2 I Amendment No. ; l (Proposed Wording)- fl < l e

                                ,-                       ,~                          . - ,         ,,                 - . -         ,,.

, ...y . . _ , - . - - . . . _ . . . - ._. 6 NPF-73 [ INDEX ,

                                                                                                                                                   'i
 .      ' DEFINITIONS                                                                                                                                !

{ 1 SECTIO'N' PAGE ; 1.23 ENGINEERED SAFETY FEATURE RESPONSE TIME . . . - - . . - . . 1-4' r t 1.24 AXIAL-FLUX DIFFERENCE . . . . . . . . , . . . . . . .-.- . 1-4 :l 1.25 PHYSICS TEST . . . . . . . . . . . . . . . . . . . .. .. 1-5 ! 1.26 E-AVERAGE DISINTEGRATION ENERGY . . . . . . . . . .. . . 1-5 -' i 1.27 SOURCE CHECK . . . . . .. . . . . . .. . . . . . . .. . . 1-5

                                                                                                                                                   .t 1.28    PROCESS CONTROL PROGRAM                      . . . . . . . . . . . . . ..                                       . 1-5              :

1 1.29 SOLIDIFICATION . . . . . . . . . ... . . .. . . . . . . 1-5.. -[ 1.30 OFF-SITE DOSE CALCULATION MANUAL (ODCM) . . . . . . . . 1-5. 3 f 1.31 GASEOUS RADWASTE TREATMENT SYSTEM- . . . . . . . . . . . 1-5 , 1,32 VENTILATION EXHAUST TREATMENT SYSTEM . . . . . . . . . 1-6 i 1.33 PURGE - PURGING . . . . . . . . . . . . . . . . . . . . 1-6 , 1.34 VENTING . . . . . . . . . . . . . . . . . . . .. . . . . 1-6 -i i 1.35 MAJOR CHANGES . . . . . . . . . . . . . . . . . . .. . 1-6 i 1.36 MEMBER (S) OF THE PUBLIC . . . . . . . . . . . . . . . . 1-7 l TABLE 1.1 OPERATIONAL MODES (TABLE 1.1) . . . . ' . . . . - . . . . . 1-8 , TABLE 1.2 FREQUENCY NOTATION . . . . . . . . . . . . . . . . .. 1-9 [ i 1 l l l 1 1 i BEAVER VALLEY - UNIT 2 II Amendment No.. -l (Proposed Wording) a l

NPF-731 INDEX BASES SECTION PAGE '3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE . . . . . B 3/4 4-4 3/4.4.7 CHEMISTRY . . . . ........... B 3/4 4-5 3/4.4.8 SPECIFIC ACTIVITY ........... B 3/4 4-5 3/4.4.9 -PRESSURE / TEMPERATURE LIMITS . . . . . . B 3/4.4 3/4.4.10 STRUCTURAL INTEGRITY . . . . . . . . . . B 3/4 4 3/4.4.11 RELIEF VALVES . . ........... B 5/4 4-16 3/4.4.12 REACTOR COOLANT SYSTEM HEAD VENTS . . . B 3/4.4-16' 3/4.5 DIERGENCY ' CORE COOLING SYSTEMS (ECCS) l 3/4.5.1 ACCUMULATORS . . . ........... B 3/4 5-1 f 3/4.5.2 AND 3/4.5.3 ECCS SUBSYSTEMS . . . . . . . . . B 3/4 5-1 l 3/4.5.5 (MOVED TO BASES SECTION 3/4.1.2) i 3/4.6 CONTAINMENT SYSTEMS 1 h 3/4.6.1 PRIMARY CONTAINMENT . . . . . . . . . . . B 3/4 6-1 j 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS . . . B 3/4 6-10' i t 3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . . B 3/4 6-10 '! t 3/4.6.4 COMBUSTIBLE GAS CONTROL B 3/4 6-11

3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM . . B 3/4 6-11 1

~!

l 3/4.7 PLANT SYSTEME ! 3/4.7.1 TURBINE CYCLE . . ......... . . . B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE' LIMITATION . . . ............ B 3/4 7-3 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM , . B 3/4 7-3 l 3/4.7.4 SERVICE WATER SYSTEM . . . . . . . . . . . B 3/4 7-3 3/4.7.5 ULTIMATE HEAT SINK . . . . . . . . . . . . B 3/4 7-3 3/4.7.6 FLOOD PROTECTION . ............ B 3/4 7-4 3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEM . . . . . . ............ B 3/4 7-4 3/4.7.8 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS) . . ............ B 3/4 7-4 3/4.7.9 SEALED SOURCE CONTAMINATION . . . . . . . B 3/4 7-5 3/4.7.12 SNUBBERS . . . . . . . . . . . . . . . . . . B 3/4 7-5 BEAVER VALLEY - UNIT 2 XI (Proposed Wording)

NPF-73 DEFINITIONS '! CONTAINMENT INTEGRITY (Continued) !

b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except- as provided in Table .

3.6-1 af Specification 3.6.3.1. 1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each air lock is in compliance with the requirements l-of Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and I 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) is OPERABLE. CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range . and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel i including the sensor and alarm and/or trip functions, and shall- , include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be a performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated. ' CHANNEL CHECK 1.10 A CHANNEL CHECK shall be the qualitative assessment of - channel behavior during operation by. observation. This determination shall include, where possible, comparison of.the channel indication and/or status with other indications and/or status derived from , independent instrument channels measuring the same parameter. , CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to.the primary sensor as 1 practicable to verify OPERABILITY including alarm and/or trip functions. - CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS , shall not preclude completion of movement of a component to a safe , conservative position.

                                                                              -l
 . BEAVER VALLEY - UNIT 2              1-2                 Amendment No.

(Proposed Wording) k

NPF-73 DEFINITIONS , SHUTDOWN MARGIN 1.13 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is or would be suberitical from its present condition assuming all full length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be , fully withdrawn. IDENTIFIED LEAKAGE 1.14 IDENTIFIED LEAKAGE shall be:

a. Leakage (except CONTROLLED LEAKAGE) into closed-systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or

c. Reactor Coolant System leakage through a steam generator to the secondary system.

UNIDENTIFIED LEAKAGE 1.15 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE. PRESSURE BOUNDARY LEAKAGE 1.16 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam , generator tube leakage) through a non-isolable fault in-a Reactor Coolant System component body, pipe wall or vessel wall. CONTROLLED LEAKAGE 1.17 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor coolant pump seals. OUADRANT POWER TILT RATIO , 1.18 QUADRANT POWER TILT RATIO shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one (1) excore detector inoperable, the remaining three (3) detectors shall be used for computing the average. BEAVER VALLEY - UNIT 2 1-3 Amendment No. (Proposed Wording)

l l NPF-73 I DEFINITIONS-DOSE EOUIVALENT I-131 1.19 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (1ci/ gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid-dose conversion factors used ' for this calculation shall be those listed in Regulatory Guide ' 1.109, 1977 or TID 14844. STAGGERED TEST BASIS 1.20 A STAGGERED TEST BASIS shall consist of:

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

b. The testing of one (1) system, subsystem, train or other designated component at the beginning of each subinterval.

EREOUENCY NOTATION 1.21 The FREQUENCY NOTATION specified for the performance of - Surveillance -Requirements shall correspond to the intervals defined , in Table 1.2. ! i REACTOR TRIP SYSTEM RESPONSE TIME 1.22' The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time ' interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until loss of stationary gripper coil voltage. ENGINEERED SAFETY FEATURE RESPONSE TIME 1.23 The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation-setpoint at the channel sensor until the ESF equipment is capable of-performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). TJmes shall include diesel generator starting and sequence loading delays where applicable. 3 AXIAL FLUX DIFFERENCE ! 1.24 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals between the top and bottom halves of a two-section excore neutron detector. BEAVER VALLEY - UNIT 2 1-4 Amendment No. (Proposed Wording) 9

l i NPF-73 . DEFINITIONS ' PHYSICS TESTS 1.25 PHYSICS . TESTS shall be those I wts performed to measure the [ fundamental nuclear characteristics of the reactor core and related i instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 10 CFR 50.59, or 3) otherwise approved by.the commission. E - AVERAGE DISINTEGRATION ENERGY 1.26 E shall be the average sum (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half # lives greater than 15 minutes, making up.at least 95% of the total non-iodine activity in the coolant. , SOURCE CHECK . 1.27 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. 4 PROCESS CONTROL PROGRAM 1.28 A PROCESS CONTROL PROGRAM (PCP) shall be the manual or set of i operating parameters detailing the program of sampling, analysis, and evaluation by which SOLIDIFICATION of wet radioactive wastes is assured. Requirements of the PCP are provided in Specification 6.14. SOLIDIFICATION ! 1.29 SOLIDIFICATION shall be the conversion of wet radioactive wastes into a form that meets shipping and burial ground requirements. .

QFFSITE DOSE CALCULATION MANUAL LODCM) 1.30 An OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be a manual- ' containing the methodology and parameters to be used in the ; calculation of offsite dosec due to radioactive gaseous and liquid ; effluents and in the calculation of gaseous and liquid effluent - monitoring instrumentation alarr/ trip setpoints. Requirements of the l ODCM are provided in Specification 6.15. . GASEOUS RADWASTE TREATMENT SYSTEM 1.31 A GASEOUS RADWASTE TREATMENT SYSTEM is any system designed and installed to reduce radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment. , r BEAVER VALLEY - UNIT 2 1-5 Amentment No. (Proposed Wording) '

NPF-73 l DEFINITIONS r VENTILATION EXHAUST TREATMENT SYSTEM 1.32 VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed to reduce gaseous radiciodine or radioactive material , in particulate form in effluents by passing ventilation or vent ! exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust i stream prior'to the release to the environment (such a system is not t considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered ! to be VENTILATION EXHAUST TREATMENT SYSTEM components. I PURGE-PURGING t i 1.33 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, l humidity, concentration or other operating conditions, in such a manner that replacement air or gas is required to purify the confinement. l t VENTING 1.34 VENTING is the controlled process of discharging air or gas I from a confinement to maintain temperature, pressure, humidity, I concentraticn or other operating conditions, in such a manner that ; replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process. l MAJOR CHANGES ; 1.35 MAJOR CHANGES to radioactive waste systems, as addressed in ' Paragraph 6.16.2, (liquid, gaseous and solid) shall include the following: l

1) Major changes in process equipment, components, structures, 1 and effluent monitoring instrumentation _ from those !

described in the Final Snfety Analysis Report (FSAR)-or the ! i Hazards Summary Report and evaluated in the staff's Safety Evaluation Report (SER) (e.g., deletion of evaporators and installation of demineralizers; use of fluidized bed calciner/ incineration in place of cement solidification ; systems);

2) Major change = in the design of radwaste treatment systems (liquid, gascous, and solid) that could significantly increase the quantities or activity of effluents released 3 or volumes of solid waste stored or shipped offsite from i those previously considered in the FSAR and SER (e.g., use ?

of asphalt system in place of cement); i i BEAVER VALLEY - UNIT 2 1-6 Amendment No. (Proposed Wording) 4

NPF-73 DEFINITIONS : MAJOR CHANGES (Continued) l

3) Changes in system design which may invalidate the accident analysis as described in the SER (e.g., changes in tank capacity that would alter the curies released); and 3

4) Changes in system design that could potentially result in a significant increase in occupational exposure of operating [

personnel (e.g., use of temporary equipment without , adequate shielding provisions). MEMBER (S) OF THE PUBLIC 1.36 MEMBER (S) OF THE PUBLIC shall include all persons'who are not ! occupationally associated with the plant. This category does not , include employees of the utility, its contractors, or its vendors. : Also excluded from this category are persons who enter the site to service equipment or to make deliveries and persons who traverse portions of the site as the consequence of a public highway, a' railway, or waterway located within the confines of the site boundary. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant. CORE OPERATING LIMITS REPORT

1.37 The CORE OPERATING LIMITS REPORT (COLR) is the unit-specific document that provides core operating limits for the current operating reload cycle. These cycle-specific core operating limits shall be determined for each reload cycle in accordance with Specification 6.9.1.14. Plant operation within these operating- , limits is addressed in individual specifications. I r i l l BEAVER VALLEY - UNIT 2 1-7 Amendment No. (Proposed Wording)

   .            ~.                                . .

NPF-73 l TABLE 1.1 ! OPERATIONAL MODES REACTIVITY % RATED AVERAGE CONDITION, THERMAL COOLANT. , MODE K eff POWER

TEMPERATURE _

i

1. FOWER OF ATION .20.99 >5% 2350*F

2. STARTUP 20.99 s5% 2350*F t

3. HOT STANDBY <0.99 0 2350*F !

.i

4. HOT SHUTDOWN <0.99 0 350*F'>T avg [

                                                             >200'F           r

5. COLD SHUTDOWN <0.99 0. 5200*F. ;

6. REFUELING ** $0.95 0 5140'F i i

I l e l I

'l

Excluding decay heat. l
- Reactor vessel head unbolted or removed and fuel in the vessel. .

BEAVER VALLEY - UNIT 2 1-8 Amendment No. [ (Proposed' Wording) ,!

i NPF-73 TABLE 1.2 FREOUENCY NOTATION t NOTATION FREOUENCY , S At least once per 12 hours. j D At least once per 24. hours. W At least once per 7 days. M ' At least once per 31 days. i Q At least once'per 92 days.

SA At,least once perL184 days. , R At least once per 18 months. l, S/U Prior to each reactor startup. ! P Completed prior to each release. 15 N.A. Not applicable.

l

                                                                               'l 1

q i I i i l

BEAVER VALLEY - UNIT 2 1-9 Amendment No. l I (Proposed Wording) i

l t t NPF-73 3/4.6 CONTAINMENT SYSTEMS i [ 3/4.6.1 PRIMARY CONTAINMENT t CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION ! 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained. [

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

i ACTION: l I Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 l hours and in COLD SHUTDOWN within the following 36 hours. j SURVEILLANCE REQUIREMENTS l 4 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated: , i

a. At least once per 31 days by verifying that:

f I

1. All penetrations (1) not capable of being closed by. !

OPERABLE containment automatic isolation valves and i required to- be closed during accident conditions are ; closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-1 of Specification 3.6.3.1. .l

2. All equipment hatches are closed and sealed. l

b. By verifying that each containment air lock is in -;

compliance with the requirements of Specification 3.6.1.3. l j i

c. After each closing of each penetratior subject to Type B f testing, except the containment air locks, if opened l following a Type A or B test, by leak rate testing the seal with gas at a pressure not less than P a (44*7 Psig), and j verifying that when the measured _ leakage rate-for these seals is added to the leakage rates determined pursuant-to i Specification 4.6.1.2.d for all other Type B and C ,

penetrations, the combined leakage rate is less than } 0.60 L a* ! (1) Except valves, blind flanges, and deactivated automatic valves I which are located inside the containment and are locked, sealed,

       .cnr otherwise secured.in the closed position.                 These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per                     ,

92 days. ! r BEAVER VALLEY - UNIT 2 3/4 6-1 Amendment No. l (Proposed Wording) ! F

l NPF-73 CONTAINMENT SYSTEMS l l CONTAIRMENT AIR LOCKS LIMITING CONDITION FOR OPERATION 3.6.1.3 Two containment air locks shall be OPERABLE: l MODES 1, I APPLICABILITY: 2, 3 and 4. l ACTION:

 - - - - - - - - - - - - - GENERAL NOTES - - - - - - - - - - - - - -

l

1. Entry and exit is permissible to perform repairs on the I affected air lock components.

2. Separate ACTION statement entry is allowed for each air ,

lock. !

3. Enter the ACTION of LCO 3.6.1.1, when air lock leakage results in exceeding the combined containment leakage rate. I i

a. With one containment air lock door inoperable in one or '

more containment air locks:(4)

1. Verify the OPERABLE door is closed in the affected air '

lock within 1 hour, and

2. Lock the OPERABLE door closed in the affected air lock within 24 hours, and i

3. Verify the OPERABLE door is locked clog in the affected air lock at least once per 31 days.1gQ / 1

4. Otherwise, be in at least HOT STANDBY within the next ,

6 hours and in COLD SHUTDOWN within the following 30 I hours. 1 i (4) Entry and exit is permissible for 7 days under administrative controls to perform activities not related to the repair of; i affected air lock components. ; I (5) Air lock doors in high radiation areas may be verified locked i closed by administrative means. ! BEAVER VALLEY - UNIT 2 3/4 6-4 Amendment No. (Proposed Wording) l L a

NPF-73 I CONTAINMENT ofSTEMS f

~!

i LIMITING CONDITION FOR OPERATION .i t ACTION: (Continued) 4 i

b. With the containment air lock interlock :

inoperable in one or more containment air locks:(6) mechanism ;

1. Verify an OPERABLE door is closed in the affected air !

lock within 1 hour, and [

2. Lock an OPERABLE door closed in the affected air lock I within 24 hours, and j

3. Verify an OPERABLE door is locked clos 9 in the !

affectedairlockatleastonceper31 days.1g) '

4. Otherwise, be in at least HOT STANDBY within the next [

6 hours and in COLD SHUTDOWN within the following 30 hours. j I

c. With one or more containment air locks inoperable, except j as the result of an inoperable air lock door and/or ;

inoperable interlock mechanism t

1. Immediately initiate action to evaluate the combined containment leakage rate per LCO 3.6.1.2, and ;j

2. Verify a door is closed in the affected air lock, ;

within 1 hour, and

3. Restore the air lock to OPERABLE status within 24 !

hours.

4. Otherwise, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 l hours. j i

i i (5) Air lock doors in high radiation areas may be verified locked closed by administrative means. l l (6) Entry and exit of containment is permissible under control of'a I dedicated individual. l BEAVER VALLEY - UNIT 2 3/4 6-5 Amendment No. (Proposed Wording)

t , NPF-73 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS j 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE: i

a. Within 72 hours (7) following each containment entry, I except when the air entries, lockisbeingusedforn}yiple then at least once per. 72 hours, by I verifying no detectable seal leakage when the gap between the door seals is pressurized for.at least 2 minutes to:

1. Personnel air lock greater than or equal to 'l '

44.7 psig

2. Emergency air lock greater- than or equal to l 10.0 psig or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less than or equal '

to 0.0005 L a at P (44.7 psig) for the personnel l air lock and 0.8005 La at 10.0 psig for the ; emergency air lock. i

b. By conducting overall air lock leakage tests,(9) at I not less than P (44.7 psig), and verifying the !

overall air lock Seakage rate _is less than or equal to 0.05 L a at P a (44.7 psig): I- ;

1. At least.once per 6 months,(7) and l ,

2. Prior to establishing CONTAINMENT INTEGRITY when l !

maintenance has been performed on the air lock that could the air lock scaling capability,(10) affect and -l i I (7) The provisions of Specification 4.0.2 are not applicable. i (8) An inoperable air lock door doe s not invalidate the l previous successful performance o f.' the overall air lock , leakage test. l (9) .Results. shall be evaluated against the acceptance criteria j of LCO 3.6.1.2. j (10) Exemption to Appendix J of 10 CFR 50, as stated in the operating license. j

'l

( BEAVER VALLEY - UNIT 2 3/4 6-Sa Amendment No. l (Proposed Wording) li

5 NPF-73 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3. Following maintenance performed on the outer l personnel . air lock door which may result in a i decrease in closure force on any part of the door n sealing surface. .

c. At least once per 18 months during shutdown by [

verifying: s I

1. Only one door in each air lock can be opened at a time. ;

s s i h i I f i BEAVER VALLEY - UNIT 2 3/4 6-Sb Amendment No. l 1 (Proposed Wording) I , _ _ _ .

NPF-73 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENT j i 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be. restricted to .those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with the i leakage rate limitation, will limit the site boundary radiation ! doses to within the limits of 10 CFR 100 during accident conditions. ! 3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak. accident pressure, P a. As an added conservatism, the measured overall integrated leakage rate is further limited to less than or equal to 0.75 L a during ; performance of the periodic test to account for possible degradation of the containment leakage barriers between leakage tests. The surveillance testing for measuring leakage rates are i consistent with the requirements of Appendix "J" of 10 CFR 50. i 3/4.6.1.3 CONTAINMENT AIR LOCKS i BACKGROUND l Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation. Each air lock is nominally a right circular cylinder, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment. is not required to be OPERABLE, 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. The emergency air lock, which is located in the equipment hatch opening, is normally removed-from the containment building and stored during a refueling outage. Each air lock. door has been designed and-tested.to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single- door supports containment OPERABILITY. Each of the doors contains double o-ring seals and local' leakage rate testing capability to ensure pressure integrity. DBA i conditions which increase containment pressure will result in BEAVER VALLEY - UNIT 2 B 3/4 6-1 Amendment No. _, (Proposed Wording) j i

NPF-73 3/4.6 CONTAINMENT SYSTEMS s BASES , 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) BACKGROUND (Continued) increased sealing forces on the personnel air lock inner door and both doors on the emergency air lock. . The outer door on the personnel air lock is periodically tested in a manner where the : containment DBA pressure is attempting to overcome the door sealing forces. 1 The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak ' tightness is , essential for maintaining the-containment leakage rate within limits [ in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analyses. SR 4.6.1.2 leakage rate requirements comply with 10 CFR 50, Appendix J, as modified by approved i exemptions. , I APPLICABLE SAFETY ANALYSES The DBAs that result in a release of radioactive material within containment are a loss of coolant accident and a rod ejection l accident. In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.1 percent of containment air weight per day. This leakage rate is defined in 10 CFR 50, Appendix J, as L a = 0.1 percent of f containment air weight per day, the maximum allowable containment leakage rate at the calculated peak containment internal pressure P3 = 44.7 psig following a DBA. This allowable' leakage rate forms , the basis for the acceptance criteria imposed on the SRs associated with the air lockc. { LCO

                                                                                    'l Each containment air lock forms part of the containment pressure            j boundary.           As part of containment, the air lock safety function-is related to control of the containment leakage rate resulting from a                 .,

DBA. Thus, each air lock's structural integrity and leak tightness ; are essential to the successful mitigation of such an event.

s BEAVER VALLEY - UNIT 2 B 3/4 6-2 Amendment No. (Proposed Wording) .i

t NPF-73 ; 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) LCO (Continued) Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air i lock leakage test, and both air lock doors must be' OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be ! OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. I Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into and exit from containment. APPLICABILITY In Modes 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced-due to the i pressure and temperature limitations of these MODES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the i containment air locks during MODE 6 are addressed in LCO 3.9.4, t

   " Containment Building Penetrations."                                                             l l

ACTIONS , The ACTIONS are modified by_a General Note (1) that allows entry and exit to perform repairs on the affected air lock component. .If the outer door is inoperable, then it may be easily accessed to repair. If the inner door is the one that is inoperable, however, then a short time exists when the containment boundary may not be intact' -i (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 j in which the OPERABLE door is expected to be open. At no time ! should the OPERABLE door be opened if it cannot be demonstrated that-the inoperable door is sufficiently closed / latched- such that it .; could inadvertently open while the OPERABLE door is opened. After each entry and exit, the OPERABLE door must be immediately closed. BEAVER VALLEY - UNIT 2 B 3/4 6-3 Amendment No. (Proposed Wording) 1

                                                     ' ' - - -           ----sa

> $ I: I NPF-73 . . i 3/4.6 CONTAINMENT SYSTEMS ; 1 BASES

       '3/4.6.1.3          CONTAINMENT AIR LOCKS (Continued).

ACTIONS (Continued) If ALARA conditions permit and personnel safety can be assured, entry and exit should be via an OPERABLE air lock. General Note (2) has been added to provide clarification that, for this LCO, separate Action statement entry is allowed for each , air lock. In the event the air lock leakage results in exceeding the combined containment leakage rate, General Note (3) directs entry ' into the Required Action of LCO 3.6.1.1.

a. With one air lock door in one or more containment air locks inoperable, the OPERABLE door must be verified. closed' (Required Action a.1) in each affected containment air ,

lock. This ensures that a leak tight containment barrier i is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour. This specified time period is consistent with 'the Required , Action of LCO 3.6.1.1, which requires CONTAINMENT INTEGRITY , to be restored within 1 hour. : r In addition, the affected air lock penetration must be isolated by locking closed (Required Action a.2) the OPERABLE air lock door within the 24 hour Completion Time. The 24 hour Completion Time is reasonable for locking the l

OPERABLE air lock door, considering the. OPERABLE door of the affected air lock is being maintained closed. This -i action places additional positive controls on the use of i the air lock when one air lock. door is inoperable. Required Action a. has been modified by a Note.- Notel (4) allows use of the air lock for entry and exit for 7 days. ;

under administrative controls. Containment entry may:be required to perform non-routine Technical Specification' l (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. An example of such an activity ~i would be the isolation-of a containment penetration by at , least one operable valve, and the subsequent repair and l' post-maintenance technical specification surveillance testing on. the inoperable valve. In addition,-containment! . entry may be required to perform repairs on vital plant '; equipment which, if not repaired, could lead to a plant

       ' BEAVER VALLEY - UNIT'2                      B 3/4 6-4                       Amendment No.              l (Proposed Wording)                                                  .;

MPF-73 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) ACTIONS (Continued) > transient or reactor trip. This Note is not intended to . preclude performing other activities (i.e., non-TS-required activities or repair of non-vital plant equipment) if the - containment is entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance e 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. Required Action a.3 verifies that an air lock with an inoperable door. has been isolated by the use of a locked and closed OPERABLE air lock door. This ensures that an acceptable containment leakage boundary is maintained. The Completion Time of once per 31 days is based on engineering judgment and is considered adequate in view of the low likelihood of a locked door being mispositioned. Required Action a.3 is modified by a Note (5). that applies to air lock doors located in high radiacion areas and allows these doors to.be verified locked closed by use of administrative r means. Allowing verification by administrative means is considered acceptable, since access to these areas is-

typically restricted. Therefore, it is unlikely that a door would become misaligned once it has been verified to be in the proper position.

b. With an air lock interlock mechanism inoperable in one or !

more air locks, the Required Actions 'and associated ' Completion Times are consistent with those specified in Required Action a. The Required Actions have been modified by two Notes. Note (6) allows entry into and exit from containment 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). Note (5) applies to air lock doors located in high radiation , areas and allows these doors to be verified locked closed by use. of administrative means. Allowing verification by - administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, it is ! unlikely that a door would become misaligned once.it has , been verified to be in the proper position. l BEAVER VALLEY - UNIT 2 B 3/4 G-5 Amendment No. l (Proposed Wording) b

NPF-73 , ~3/4.6 CONTAINMENT SYSTEMS , BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) ACTIONS (Continued)

g. With one or more air locks inoperable for reasons other than those described in Required Actions a or b, Required Action c.1 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 limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour (per LCO 3.6.1.1) 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 combined containment leakage rate can still be within limits. Required Action c.2 requires that one door in.the affected containment air lock must be verified to be closed within the 1 hour Completion Time. This specified time period is consistent with the Required Actions of LCO 3.6.1.1, which requires that CONTAINMENT INTEGRITY be restored within 1 hour. Additionally, Required Action c.3 requires that the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, assuming that at least one. , door is maintained closed in each affected air lock. For all Required Actions, if the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not i apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within the following 30 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. BEAVER VALLEY - UNIT 2 B 3/4 6-6 Amendment No. l (Proposed Wording)

l I NPF-73 l 3/4,6 CONTAINMENT SYSTEMS BASES j l l l 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued)

SURVEILLANCE REOUIREMENTS (SR) l l l Maintaining containment air locks OPERABLE requires compliance l l with the leakage rate test requirements of 10 CFR 50, Appendix J, as ) modified by approved exemptions. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The periodic testing requirements verify that_the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by Appendix J, as modified by approved exemptions. Note (10) reflects the current l approved exemption from Appendix J. Thus, SR 4.0.2 (which allows Frequency extensions) does not apply as stated in Note (7). Testing of the personnel air lock door seals may be accomplished with the air lock pressure equalized with containment or with atmospheric pressure. Each configuration applies P , as a minimum, across the sealing surfaces demonstrating the ability to function as designed. As long as the testing conducted .is ; equivalent or more conservative than what might exist for accident i conditions, the air lock doors will be able to perform their design 1 function. Performance of maintenance activities which affect. air lock sealing capability, such as the replacement of the o-ring door seals and/or breach ring travel adjustment, will require performance of the appropriate surveillance requirements such as SR 4.6.1.3.a as a , i minimum. The performance of SR 4.6.1.3.b will depend on the air 'l' l lock components which are affected by the maintenance. Replacement of o-rings and/or breech ring travel adjustment on the inner personnel air lock door, for example, normally will not require the performance of SR 4.6.1.3.b as a post maintenance test. Testing per SR 4.6.1.3.a is sufficient to demonstrate post accident leak tightness of the inner air lock door. The sealing force, which is applied to o-rings, is developed by the rotation of tapered wedges L against the door's outer surface. This action forces the door to I compress the o-rings which are located on the air lock barrel. When SR 4.6.1.3.a is performed, the area between the two concentric o-rings is pressurized to at least P a and a leak rate of the two o-rings and sealing surface is determined. This test pressure applies an opposing force to the breech ring closure force. Since the containment pressure developed during a DBA applies a closing force which is supplemental to the breech ring force, the net result would be to improve the door sealing capability of the inner personnel air lock door over that which exists during the performance of SR 4.6.1.3.a. For this reason, performance of SR l BEAVER VALLEY - UNIT 2 B 3/4 6-7 Amendment No. l (Proposed Wording)

1 NPF-73 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) SURVEILLANCE REOUIREMENTS (SR) (Continued) i 4.6.1.3.b, which applies a force which opposes the breech ring force, is not necessary following certain inner air lock door maintenance. SR 4.6.1.3.a sufficiently demonstrates the ability of the inner air lock door to provide a leak tight barrier following ! maintenance affecting the door sealing surface. Replacement of the o-rings on the outer personnel air lock door, which results in decreasing the breech ring closure force, will require performance of SR 4.6.1.3.b in addition to SR 4.6.1.3.a which is required due to the door beino opened. This surveillance is required because containment DBA prassure tends to overcome the outer personnel air lock door sealing forces. Performance of SR 4.6.1.3.a on the outer personnel air lock applies an opposing force to the breech ring closure force in the same manner as previously described for the inner personnel air lock door. However, for the outer personnel air door, the containment pressure developed during a DBA applies an opening force which is opposing the breech ring closure force. Therefore, upon completion of certain maintenance activities, continued outer door leak tightness during a DBA cannot be assured by performance of SR 4.6.1.3.a alone. Maintenance which may result in a decrease in closure force on any part of the door , sealing surface, (decreasing of breech ring travel for example), will require performance of SR 4.6.1.3.b. The performance of this surveillance is necessary to ensure that containment DBA pressure applied against the outer door will not result in the unseating of the air lock door by overcoming of the breech ring closure forces to the point where the leakage becomes excessive. Since SR 4.6.1.3.b duplicates LBA forces on the outer personnel air lock door and also measures the air lock leakage rate, performance of this surveillance-requirement demonstrates the continued ability of the outer personnel air lock dor " to provide a leak tight barrier, during a DBA, following specific maintenance activities. The air lock interlock is designed to prevent simultaneous i opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY and personnel safety, considering the subatmospheric design, while the air lock is'being used for personnel transit in and out of the containment. Periodic I testing of this interlock demonstrates that the interlock will- ) function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. i 1 BEAVER VALLEY - UNIT 2 B 3/4 6-8 Amendment No. l (Proposed Wording) l 1 [-

NPF-73 3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1.3 CONTAINMENT AIR LOCKS (Continued) SURVEILLANCE REOUIREMENTS (SR) (Continued) The SR has been modified by two additional Notes. Note (8) states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage , test. This is considered reasonable since either air lock door is ! capable of providing a . fission product barrier in the event of a. : DBA. Note (9) has been added to this SR requiring the results to be j evaluated against the acceptance criteria of LCO 3.6.1.2. This ensures that air lock leakage is properly accounted for in determining the combined containment leakage rate. 3/4.6.1.4 and 3/4.6.1.5 INTERNAL PRESSURE AND AIR TEMPERATURE The limitations on containment internal pressure and average air temperature as a function of service water temperature ensure that

1) the containment structure is prevented from exceeding its design negative pressure of 8.0 psia, 2) the containment peak pressure does not exceed the design pressure of 45 psig during LOCA conditions, i and 3) the containment pressure is returned to subatmospheric conditions following a LOCA.

The containment internal pressure and temperature limits shown as a function of service water temperature _ describe the operational , envelope that will 1) limit the containment peak pressure to less than its design value of 45 psig and 2) ensure the containment internal pressure returns subatmospheric within 60 minutes following , a LOCA. The limits on the parameters of Figure 3.6-1 are consistent with the assumptions of the accident analyses. 1 3/4.6.1.6 CONTAINMENT STRUCTURAL INTEGRITY , This limitation ensures that the structural integrity of the containment vessel will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the vessel-will withstand the maximum pressure of 44.7 psig in the event of a LOCA. The visual and Type A leakage tests are sufficient to demonstrate this capability. i l BEAVER VALLEY - UNIT 2 B 3/4 6-9 Amendment No. l . (Proposed Wording) I

'NPF-73 3/4.6 CONTAINMENT-SYSTEMS BASES 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT OUENCH AND RECIRCULATION SPRAY SYSTEMS The OPERABILITY of the containment spray systems ensures that. I containment depressurization and subsequent return to subatmospheric pressure will occur in the event of a LOCA. The pressure reduction and resultant termination of containment leakage are consistent with the assumptions used in the accident analyses. The recirculation spray system consists of four 50 percent capacity subsystems each composed of a spray pump, associated heat exchanger and flow path. All recirculation spray pumps and motors are located outside containment and supply flow to two 360' recirculation spray ring headers located in containment. One spray ring is supplied by the "A" train subsystem containing recirculation spray pump 2RSS-P21A and the "B" train subsystem containing recirculation spray pump 2RSS-P21D with the other spray ring being > supplied by the "A" train subsystem containing recirculation spray pump 2RSS-P21C and the "B" train subsystem containing recirculation. spray pump 2RSS-P21B. When the water in the refueling water storage tank has reached a predetermined extreme -low level, the C and D subsystems are automatically switched to the cold leg recirculation mode of emfergency core cooling system operation. . .

                                                                                    -l 3/4.6.2.3     CHEMICAL ADDITION SYSTEM                                               l I

The OPERABILITY of the chemical addition system ensures that. l sufficient NaOH is added to the containment spray in the event of a LOCA. The limits on NaOH minimum volume and concentration,' ensure that 1) the iodine removal efficiency of .the spray water is maintained because of the increase in pH value, and 2) corrosion effects on components within containment are ' minimized. These assumptions are consistent with- the iodine removal efficiency assumed in the accident analyses. 3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of.the containment isolation-valves ensures'that the containment atmosphere will be isolated from the outside -j environment in the event of a release of radioactive material to the containment atmosphere or pressurization of .the containment' . I Containment isolation within the time limits specified ensures.that ; the release of radioactive material to 'the environment will be consistent with the assumptions used in the analyses for both_a LOCA

.and major secondary system breaks.                                                 ]

i BEAVER VALLEY - UNIT 2 B 3/4 6-10 Amendment No. -l (Proposed Wording)

NPF-73 CONTAINMENT SYSTEMS BASES i 3/4.6.4 COMBUSTIBLE GAS CONTROL The OPERABILITY of the equipment and systems required for the ' detection and control of hydrogen gas ensures that this equipment will be available to maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions. Either recombiner unit is capable of. controlling .the expected hydrogen generation associated with 1) zirconium-water reactions,

2) radiolytic decomposition of water 3) corrosion of metals within ;

containment. These hydrogen control systems.are consistent with the - recommendations of Regulatory Guide 1.7,-" Control of Combustible Gas Concentrations in Containment Following a LOCA." 3/4.6.5 SUBATMOSPHERIC PRESSURE CONTROL SYSTEM 3/4.6.5.1 STEAM JET AIR EJECTOR f The closure of the manual isolation valves in the suction of the , steam jet air ejector ensures that 1) the containment internal 4 pressure may be maintained within its operation limits by.the i mechanical vacuum pumps and 2) the containment atmosphere is isolated from the outside environment in the event of a LOCA. These valves are required to be closed for containment isolation. i Y BEAVER VALLEY - UNIT 2 B 3/4 6-11 Amendment No. : (Proposed Wording) ) i 4

l l ATTACHMENT D-1 l Beaver Valley Power Station, Unit No. 1 ; Proposed Technical Specification Change No. 199, Revision 1 The following is a list of the affected page: - Affected Page: 3/4 6-Sb l t b 1 i

                                                                                . /, e P

i h v v

m=_ = _ _ _ 9A- % p b be re4p J 6,eJL4 DPR-66 CONTAINMENT SYSTEMS ' 4h pro c e5 tchwhl i e) t h

ARbd A-i. l SURVEILLANCE REQUIREMENTS 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:

a. Within 72 hours (7) following each containment entry, I except when the air entries, lockisbeingusedformgiple.

then at least once per 72 hours, by I verifying no detect.1ble seal leakage when the gap between the door seals is pressurized for at least 2 minutes to:

1. Personnel air lock greater than or equal to I 40.0 psig

2. Emergency air lock greater than .or equal to l 10.0 psig i or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less than or equal to 0.0005- L a at P (40.0 psig) for the personnel ,

air lock and 0.8005 L a at 10.0 psig for the ' emergency air lock. ,

b. By conducting overall air lock leakage tests,(9) at I-not less than P (40.0 psig), and verifying the overall air lock Seakage rate is less than or equal to i

j 0.05 L a at P a (40.0 psig): .i

1. At least once per 6 months,(7) and i

2. Prior to establishing CONTAINMENT INTEGRITY when !

maintenance has been performed on the air lock that coul the air lock sealing -

10) afand f ect

capability,i fi. c.\ 6K coke. heAm i

1 pesson. J w.h 1.ss P.d.,=\ a g be 54 A.hud la on ou M . or tout 4.A Art AM cley enh, (7) The provisions of Specification 4.0.2 are not applicable. ! (8) An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. (9) Results shall be evaluated against the acceptance criteria of LCO 3.6.1.2. (10) Exemption to Appendix J of 10 CFR 50, dated November- W , 1 f 1984. -- b BEAVER VALLEY - UNIT 1 3/4 6-Sb Amendment No. l (Proposed Wording) i

ATTACHMENT D-2 [ Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 66, Revision 1 : The following is a list of the affected pages: , Affected Pages: License Page 6 3/4 6-Sa i l 9

h i f e i i 1 1 1

                                                                                       .i i

I

r (Locd ledd to\tdes > NPF-73 d ca p et3Twa. o f m h:3 3

                                                                   %Q           % Sik sk.kob Est'
                                                         ~   ~

a hnwooerw\\ ckgw perm airs. bd 4 =31 , safety injection system, and residual heat removal system. This exemption will expire when the current GDC 4 rulemaking changes have been completed. (2) The facility reautres an exemption from the requirements of 10 CFR 50, Appendix J Section III.D.2(b)(11). The justification of this exemption is contained in Section 6.2.6 of Supplement 5 {**A *g T to the Safety Evaluation Report, The staff's environmental e f 1 assessment was published on May if, 1987 (52 FR 17651) d Therefore, i 1 Ake A.ba , pursuant to 10 CFR 50.12(a)(1) and 10 CFR 50.12(a)(2)(ii) and @ j (iii), Beaver Valley Power Station Unit 2 is exempt from the ; quoted requirement and instead, is required to perform the overall ~ air lock leak test at pressure P before establishing containment integrity if air lock maintenanc$ has been performed that could affect the air lock sealing capability. x { (3) The facility was previously granted an exemption from the i criticality alarm requirements of 10 CFR 70.24 (see License No. SNM-1954 d.ted April 9, 1986, which granted this exemption). Beaver Valley Power Station, Unit 2 is hereby exempted from the criticality alarm system provisions of 10 CFR 70.24 so far as ' this section applies to the storage of fuel assemblies held under this license. E. Physical Security DLCo shall fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards i contingency plans previously approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain safeguards information protected under 10 CFR 73.21, are entitled: !

                        " Beaver Valley Power Station Security Plan," with revisions submitted through April 15, 1987; " Beaver Valley Power Station Security Training and Qualification Plan," with revisions submitted through April 15, 1987; and Beaver Valley Power                   :

Station Security Contingency Plan," with revisions submitted l through February 19, 1987. > F. Fire Protection Program (Section 9.5.1 of SER Supplement 3) DLCo shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final _ Safety Analysis Report through Amendment No.17, and and submittals dated May 18, May 20, May 21, June 24 and July 6, 1987, and as : described in the Safety Evaluation Report dated October 1985, ' and Supplements 1 through 6, subject to the following provision: Oroposeb UUsh . i r

NPF-73 Noke I M g hc3 6 h CONTAINMENT SYSTEMS ADed et pre M ch IdcMIMed "s h A\kodw%s,k A-2, SURVEILLANCE REQUIREMENTS 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:

a. Within 72 hours (7) following each containment entry, I except when the air lockisbeingusedform}piple entries, then at least once per 72 hours, by l-verifying no detectable seal leakage when the gap between the door seals is pressurized for at least 2 minutes to:

1. Personnel air lock greater than or equal to' l 44.7 psig

2. Emergency air lock greater than or equal to l [

10.0 psig or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less than or equal to 0.0005 L a at P (44.7 psig) for the personnel' : air lock and 0.8005 L a at 10.0 psig for the emergency air lock,

b. By conducting overall air lock leakage tests,I9) at I not less than P (44.7 psig), and verifying the overall air lock Seakage rate is less than or equal to 0.05 L a at P a (44.7 psig): 1

1. At least once per 6 months,(7) and l-

2. Prior to establishing CONTAINMENT INTEGRITY when. .

maintenance has been performed on the air lock that coul the air lock sealing capability,g10) affect and 1-

ot n ,\ was b & q be s4s4*3 - d esi3n pi\s, (&canew-ncarhcdh*hwbn\k _ (7) The provisions of Specification 4.0.2 are not applicable. ) (8) An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. (9) Results shall be evaluated against the acceptance criteria' j of LCO 3.6.1.2. (10) Exemption to Appandix J of- 10 CFR 50, as stated in the l operating license.

BEAVER VALLEY - UNIT 2 3/4 6-Sa Amendment No. ! (Proposed Wording) l i t

ATTACHMENT E Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 199 and 66, Revision 1 PROPOSED EXEMPTION TO 10 CFR 50 APPENDIX J A. DESCRIPTION OF AMENDMENT REQUEST For Beaver Valley Power Station (BVPS) Unit No. 1, Surveillance Requirement (SR) 4.6.1.3.b.2 would be modified by the addition of the words " Local leak rate testing at a pressure of not less than P may be substituted for an overall air lock test where the d$ sign permits." Footnote (10) would be modified to reference a new letter date for the exemption to Appendix J of 10 CFR 50. The remaining proposed changes to Technical Specification page 3/4 6-5b are described in Attachment "B" of this document. For BVPS Unit 2, the license section D.2 would be modified by the addition of the words " Local leak rate testing at a pressure of not less than P may be substituted for an overall air lock test where the design permits." In addition, license section D.2 would be modified to reference a new letter and publication date which would result if this exemption request is approved. SR 4.6.1.3.b.2 would be modified by the addition of the words " Local leak rate testing at a pressure of not less than P a may be substituted for an overall air lock test where the design permits." The remaining proposed changes to Technical Specification page 3/4 6-Sa are described in Attachment "B" of this document. B. BACKGROUND November 19, 1984, BVPS Unit No. 1 was granted an exemption to i On the requirements of 10 CFR 50 Appendix J, Section III.D. 2 (b) (ii) . BVPS Unit No. 2 was granted the same exemption in 1987 as part of the issuance of the plant's operating-license. Our current exemption allows substituting the seal leakage test of Section III.D. 2 (b) (iii) of Appendix J when no maintenance that could affect sealing capability has been performed on an air lock. This requirement is reflected in our current Technical Specification SR 4.6.1.3.b.2. C. JUSTIFICATION

~_

The proposed revision would incorporate additional wording to our current exemption to 10 CFR 50 Appendix J, Section III.D.2 (b) (ii) . Appendix J states that " air locks opened during periods when containment integrity is not required by the plant technical specifications .shall be tested at the end of such

                                              "     Our    current   exemption    to periods     at not less than         P a.

Appendix J requires the overall air lock leakage test be performed, before establishing containment integrity, if air lock maintenance has been performed that could affect the air lock scaling capability. E-1

ATTACHMENT E, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 2 The proposed additional wording would allow maintenance to be performed on the air lock, that could affect its sealing , capability, without directly resulting in the required performance of the overall air lock leakage test. Performance of the overall air lock test is very time consuming (approximately 4 to 6 hours) and results in additional personnel radiation exposure. The performance of this testing during a plant shutdown can result in a delay in plant restart. When the design ! of the affected air. lock component (s) permits local leak testing at not less than P then this type of testing'is proposed to ; be substituted for t$e, overall air lock leakage test. The words "where the design permits" requires that the two criteria for testing be met. The first criteria, is that component, which has had maintenance performed on it, has local leak rate . test i' provisions factored into its design, i.e., some provisions to allow local pressurization of the component. The second criteria, is that by only locally pressurizing the affected component, the leak rate, which is then measured, must be equivalent to or more conservative than the leak rate which would ; be measured on that component during the performance of the overall air lock leakage test. For example, as discussed in the : proposed Bases for the air lock surveillance requirements ! contained in Attachment B, locally leak testing of the outer personnel air lock door following maintenance .hich w reduces ; breech ring closure force, may not provide an accurate representation of the docr's leak tightness during a DBA. Therefore, the leak rate measured during the local leak testing would not be equivalent or more conservative than the. actual leakage rate that the outer door may exhibit during the overall - air lock test. In this case, local leakage rate testing cannot be substituted for the overall leakage test since the design, i.e., the door is unseated by DBA containment pressure, of the l outer personnel air lock door does not permit conclusive test results to be obtained. I The local leakage test would involve the pressurization of the ; affected component to at least P a. A leakage rate would then I be measured in accordance with the requirements of Appendix J. The typical air lock components which could be tested in-this manner are components such as the o-ring seals on the personnel-air lock door (s), the mechanical- penetrations for the 18l inch ; escape hatches, and the equalizing valves located on each of the i I air lock doors. For each of these -components, the. design configuration permits local pressurization of the components to-at least P a' 1 1 E-2

n - ATTACHMENT E, continued : Proposed Technical Specification Change Nos. 199 and 66, Revision 1 j Page 3 i When maintenance is completed on a component which has local leak testing capability,- i.e., o-ring replacement on the air lock doors, an overall air lock leakage test does not demonstrate both barrier (o-rings) are functioning as designed. The overall test pressurizes the inside of tne air lock which ultimately only demonstrates a cealing capability of one of =two o-rings per door. A local leak test where the area between the o-rings is i pressurized demonstrates the sealing capability of both o-rings. ' This method of testing results in a better demonstration of'the sealing capability of the doors following replacement of the o-rings where breech ring closure forces are not reduced. l The ability of these components to provide a leak tight barrier, following maintenance activities, can be demonstrated during _ simulated post-accident conditions, i.e., at Pa pressure. If [ the component, which is affected by maintenance activities, ; cannot be locally leak tested at P a, such as the door seals on' the emergency air lock or the sight glasses on the personnel air , lock, then the overall air lock leakage test will be performed. > t The proposed change will allow local leakage rate testing to be su.wtituted for the overall air lock leakage test when the design of the components permits local leakage rate testing at pressure of at least P a. This proposed change is sufficient to achieve the underlying purpose of the requirements of 10 CFR .0 5 Appendix J, Section III . D. 2 (b) (ii) because it provides adequate , assurance of continued leak tight integrity of the air' lock (s). ! The methodology, that a local leak test at P a on affected air lock components is sufficient to demonstrate continued overall

air lock leak tightness, is consistent with the methodology used when another part of the containment pressure boundary is breached. When the containment equipment hatch closure is removed for refueling, for example, the o-ring seals are wiped down and re-greased and/or replaced. The only testing which is !

performed following this activity is the-local Type B test on the o-ring seals at P. a The overall containment leak rate test is ' not required when maintenance has been performed on components which make up the containment pressure boundary that affected its sealing capability. Therefore, based on the current accepted practice of locally leak testing other components in the containment pressure boundary at ' P in lieu of performing an overall containment leak test, we b$lieve it is justified to use this same methodology for maintenance activities on the air lock (s). i E-3

7 ATTACHMENT-E, continued ; Proposed Technical Specification Change Nos. 199 and 66, Revision 1 i Page 4 , h D. SAFETY ANALYSIS i The proposed change will continue to ensure that each containment : air lock will perform its safety function as part of the ! containment to control offsite radiation exposures resulting from l a design basis accident (DBA). The structural integrity and leak , tightness will not be changed as a result of this proposed l revision. The proposed change will only involve the substitution l of one test method for another test method, i.e., local leak testing for overall leak testing where the design permits. Local i leak testing will more effectively demonstrate the sealing , capability of redundant seals. The affected air lock components ! will continue to be leak tested at a test pressure equal to or greater than the calculated peak containment internal pressure

related to a DBA. The leak rate determined for an air lock component, during the local leak rate testing, will be factored ;

into the combined containment leak rate to ensure continued compliance with the maximum permissible leak rate of 0.60 L a for penetrations subject to Type B and C leak rate testing. , Therefore, this change is considered safe based on the continued l ability of the contair. ment air locks to provide a leak tight barrier, under maximum post-accident containment pressure, to ' prevent the release of radioactive materials from a DBA to ensure the limits established by 10 CFR 100 are not exceeded. E. NO SIGNIFICANT HAZARDS EVALUATION , The no significant hazard considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below: The Commission may make a final determinati;n, pursuant to the procedures in paragraph 50.91, that a proposed amendment , to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves _ no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of-accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. E-4 , e

r ATTACHMENT E, continued Proposed Technical Specification Change Nos. 199 and 66, Revision 1 Page 5 The followilg evaluation is provided for the no significant hazards consideration standards.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The probability of occurrence of a previously evaluated accident is not increased because the containment air locks do not effect the initiation of any design basis accident. The consequences of an accident are not significantly increased because the containment air locks will continue to provide a barrier to limit leakage from containment during a DBA. The combined- containment leakage limit of 0.60 L will continue to be met. The performance of a local leak rate test at P a, in place of the overall air lock leakage test, will provide adequate assurances of the continued integrity of the air locks. Therefore, based on the continued ability of the containment air locks to provide a barrier to limit leakage from containment during a- DBA, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

Air lock operation does not interface with the reactor coolant pressure boundary. or any other mechanical or electrical controls which could impact the operations of the reactor or its direct support systems. Containment air locks are designed for the purpose of containment entry and exit. During this operation, the air lock maintains containment integrity by providing at least one door which is capable of restricting release during-a DBA. The proposed change will continue to ensure that air lock operation is performed as assumed in the original design of the plant. Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident'previously evaluated. E-5

r. ATTACHMENT E, continued Proposed Tecnnical Specification Change Nos. 199 and 66, Revision 1 l; Page 6-

3. Does the change involve a significant reduction in a margin of safety? {

The applicable margin of safety consists of maintaining _the primary containment leak rates within the assumptions of the DBA analysis. The proposed change continues.to ensure that the overall air lock leak rate is maintained within the .i limits required by the plant's technical specification following maintenance activities which could affect air lock sealing capability. Local leak rate testing, at'a pressure of at least P g, will provide adequate assurance of the , continued integrity of the air lock. ; Therefore, since the primary containment leak rates will continue to be maintained within the assumptions of.the DBA analysis, this _ proposed change does not involve a significant reduction in a margin of safety. F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that , the activities associated'with this license amendment request and exemption request satisfies the no significant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards consideration finding is justified. P E-6

r. o ATTACHMENT F-1 Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 199, Revision 1 l h

                                                                                                      .i Applicable Typed Page b

h h i P 9 i f a s t i l I

a ATTACHMENT TO LICENSE AMENDMENT NO. FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following page of Appendix A, Technical Specifications, with the enclosed page as indicated. The revised page is identified by amendment number and contains vertical lines indicating the areas of change. Remove Insert 3/4 6-5b 3/4 6-Sb (Proposed Wording)

DPR-66 CONTAINMENT SYSTEMS l SURVEILLANCE REQUIREMENTS P 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE: P

a. Within 72. hours (7) following each containment 1 entry, except when the air lock isbeingused-form}piple '

entries, then at least once per. 72 hours, by verifying no detectable seal leakage when the gap between the door seals is pressurized for at least 2 minutes to:

1. Personnel air lock greater than or equal to 40.0 psig

2. Emergency air lock greater than or equal to 10.0 psig by quantifying (8) or, the air lock door seal leakage to ensure that the leakage rate is less than or equal to 0.0005 L at P (40.0 psig) for the personnel air lock anh 0.000$ L a at 10.0 psig for the emergency air lock,

b. By- conducting overall air lock leakage tests,(9) at l not less than P (40.0 psig), and verifying the overall air lock Seakage rate is less than or equal to 0.05 L a at P a (40.0 psig): ;

1. At least once per.6 months,(7) and i

2. Prior to establishing CONTAINMENT INTEGRITY when maintenance has been performed on the air lock that could affect the air lock sealing ;

capability. Local leak rate testing at a pressure l ; of not less than P a may be substituted for an. ! overall pir lock test where the' design permits,(10; and (7) The provisions of Specification 4.0.2 are not applicable. ll (8) An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. (9) Results shall be evaluated against the acceptance criteria of LCO 3.6.1.2. (10) Exemption to Appendix J of 10 CFR 50, dated . l l l i BEAVER VALLEY - UNIT 1 3/4 6-Sb Amendment No. (Proposed Wording) l

ATTACHMENT F-2 Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification change No. 66, Revision 1 Applicable Typed Pages i i f i 9 i 4 l l i 1

I- -r l ATTACHMENT TO LICENSE AMENDMENT NO. , FACILITY OPERATING LICENSE NO. NPF-73 QQCKET NO. 50-412 : Replace the following pages of Appendix A, Technical Specifications, ' with the enclosed pages as indicated. The revised' pages are " identified by amendment number and contain vertical. lines indicating ; the areas of change. i Remove Insert l License Page 6 License Page 6 3/4 6-Sa 3/4 6-Sa I i

i I l (Proposed Wording) _ s

(l NPF-73 safety injection system, and residual heat removal system. This exemption will expire when the current GDC 4 rulemaking changes have been completed. (2) The facility requires an exemption from the requirements of 10 CFR 50, Appendix J, Section III.D. 2 (b) (ii) . The justification of this exemption is contained in Section 6.2.6 of Supplement 5 to the Safety Evaluation Report and modified by a letter dated . The staff's l environmental assessment was published on May 13, 1987 (52FR 17651) and on . Therefore, pursuant to 10 l CFR 50.12 (a) (1) and 10 CFR 50.12 (a) (2) (ii) and (iii), Beaver Valley Power Station, Unit 2 is exempt from the quoted requirement and instead, is required to perform the overall air lock leak test at pressure P a before establishing containment integrity if air lock maintenance has been performed that could affect the air lock sealing capability. Local leak rate testing at a pressure of not less than P a may be substituted for an overall air lock test where the design permits. (3) The facility was previously granted an exemption from the criticality alarm requirements of 10 CFR 70.24 (see License No. SNM-1954 dated April 9, 1986, which granted this exemption). Beaver Valley Power Station, Unit 2 is hereby exempted. from the criticality alarm system provisions of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license. E. Physical Security DLCo shall fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans previously approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain safeguards information protected under 10 CFR 73.21, are entitled:

           " Beaver   Valley Power Station Security Plan," with revisions submitted through April 15,          1987;    " Beaver Valley Power Station Security      Training   and    Qualification Plan," with revisions submitted through April 15,             1987; and Beaver      '

Valley Power Station Security Contingency Plan," with revisions submitted through February 19, 1987. F. Fire Protection Procram (Section 9.5.1 of SER Supplement 3) , DLCo shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 17, and submittals dated I May 18, May 20, May 21, June 24 and July 6, 1987, and as ; described in the Safety Evaluation Report dated October 1985, and ! Supplements 1 through 6, subject to the following provision: (Proposed Wording) Amendment No.

r -- NPF-73 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS 4.6.1.3 Each containment air lock shall be demonstrated OPERABLE:

a. Within 72 hours (7) following each containment entry, except when the air lockisbeingusedformgpiple entries, then at least once per 72 hours, by verifying no detectable seal leakage when the gap.

between the door seals is pressurized for at least 2 minutes to:

1. Personnel air lock greater than or equal to 44.7 psig

2. Emergency air lock greater than or equal to 10.0 psig or, by quantifying (8) the air lock door seal leakage to ensure that the leakage rate is less'than or equal to 0.0005 La at P (44.7 psig) for the personnel air lock and 0.8005 La at 10.0 psig for the emergency air lock.

b. By conducting overall air lock leakage tests,(9)'at not less than P (44.7 psig), and verifying the overall air lock Seakage rate is less than or equal to 0.05 La at P a (44*7 Psig):

1. At least once per 6 months,(7) and

2. Prior to establishing CONTAINMENT INTEGRITY when maintenance has -been performed on the air lock that could affect the . air. lock sealing capability. Local leak rate testing at a pressure of not less than P a may be substituted for an gfprall air lock test where the design permits, and (7) The provisions of Specification 4.0.2 are not applicable.

(8) An inoperable air lock door does' not invalidate the previous successful performance of the overall air lock leakage test. (9) Results shall be evaluated against the acceptance criteria-of LCO 3.6.1.2. (10) Exemption to Appendix J of 10 CFR 50, as stated in'the operating license. BEAVER VALLEY - UNIT 2 3/4 6-Sa Amendment No. (Proposed Wording)}}

ML20063G295

Text

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