ML20140C140

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Proposed Tech Specs Re Change to Core Alteration Definition
ML20140C140
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 03/26/1997
From:
SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20140C136 List:
References
NUDOCS 9704020098
Download: ML20140C140 (8)


Text

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Document Control Desk Attachment i TSP 970003 RC-97-0064 Page 1 of 1 SCE&G - EXPLANATION OF CHANGES Paae Affected Bar Descnotion of Chanae Reason for Chance Section 1-2 1.9 1

1) Thi.c change replaces "or 1a) The words "or manipulation of any manipulation" were deleted component" with "of any fuel, from the definition of Core sources, or reactivity control Alteration because in order to components"in the definition.

manipulate a component in the reactor vessel, movement is required. This change is also consistent with the recommendations of NUREG-1431.

1b) This change makes the definition of Core Alteration consistent with its use throughout the Technical Specifications. Core Alteration is used in those Technical Specifications which protect from or mitigate a reactivif axcursion event.

ComponE other than fuel, sources and reactivity control components will have negligible (if any) affect on core reactivity. This change is also consistent with the recommendations of NUREG-1431.

2) This change deletes
2) The word " conservative"

" conservative" from the was deleted from the definition of Core Alterations.

definition of Core Alteration to eliminate potential confusion s' 'ce there is no reference to

.lse the conservative evaluation. It is assumed

" conservative"is intended to reflect the same context as safe. This change is also consistent with the recommendations of NUREG-1431.

9704020098 970326 PDR ADOCK 0500 5

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DEFINITIONS

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CONTAINMENT INTEGRITY l

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1.7 CONTAINMENT INTEGRITY shall exist when:

i All penetrations required to be closed during accident conditions a.

i are either:

1)

Camable ofbeing closed by an OPERABLE containment automatic i

isolation valve system, or 2)

Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under adminictrative control as permitted by Specification 3.6.4, b.

All equipmenthatches are closed and sealed, Each air lock is in compliance with the requirements of c.

l Specification 3.6.1.3, d.

The containment leakage rates are within the limits of

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Specification 6.8.4.g, and

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

e.

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

. CONTROLLED LEAKAGE 1.8 CONTROLLED IJ.AKAGE shall be that seal water flow supplied to the reactor coolant pump seals.

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CORE ALTERATION s 1anEd, s v.m.% e s"it<8 Gb E

3,9,weh 1.9 CORE ALTERATION shall be the movement er -Hpuhtian of c., component within the reactor pressure vessel with the vessel head removed and fuelin the vessel. Suspension ofCORE ALTERATION shallnot preclude completion of movement of a component to a safe cenm.-dre posii. ion.

l CORE OPERATING LIMITS REPORT 1.9a The CORE OPERATING I.IMITS REPORT (COLR)is the unit cide document that provides core operatinglimits for the current operating reload e.

The cycle specific core operatinglimits shall be determined for ea eload evele m accordance with Specification 6.9.1.11. Plant operation within these operating limits is addressed in individual specifications.

DOSE EQ IVALENT I-131 1.10 DOSE EQUIVALENT I-131 shall be that concentration ofI-131 (microcurie / gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture ofI-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calcu?ation shall be those listed in Table III of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites."

SUMMER -UNIT 1 1-2 Amendment No.-E4,-1-14,135

DEFINITIONS CONTAINMENT INTEGRITY 1.7 CONTAINMENT INTEGRITY shall exist when:

a.

All penetrations required to be closed during accident conditions are either:

1)

Capable of being closed by an OPERABLE containment automatic isolation valve system, or 2)

Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves U.at are open under administrative control as permitted by Specification 3.6.4, b.

All equipment hatches are closed and sealed, c.

Each air lock is in compliance with the requirements of Specification 3.6.1.3, d.

The containmmt leakag'e rates are within the limits of Specification 6.8.4.g, and e

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

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

CONTROLLED LEAKAGE 1.8 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor coolant pump seals.

CORE ALTERATION 1.9 CORE ALTERANN shall be the movement of any fuel, sources, or reactivity control components within 0:e reactor pressure vessel with the vessel head removed and fuelin the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS REPORT 1.9a The CORE OPERATING LIMITS REPORT (COLR)is the unit specific document that provides core operating limits for the current operating reload cycle. The cycle specific core operating limits shall be determined for each reload cycle in accordance with Specification 6.9.1.11. Plant operation within these operating limits is addressed in individual specifications.

DOSE EQUIVALENT l-131 1.10 DOSE EQUIVALENT l-131 shall be that concentration of I-131 (microcurie /gramj which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131,1-132,1-133,1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table ill of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites."

SUMMER - UNIT 1 1 Amendment No. 88,110,135,

4 f-4 Document Control Desk

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Attachment II TSP 970003 RC-97-0064 Page 1 of 2 1

SAFETY EVALUATION FOR REVISING THE DEFINITION FOR j

CORE ALTERATION IN THE VIRGIL C. SUMMER NUCLEAR STATION i-TECHNICAL SPECIFICATIONS i

j Description of Amendment Reauest j

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The Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS) are being

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revised to change the definition of Core Alteration to be the movement of fuel, sources, or reactivity control components; and to delete "or manipulatie n" and " conservative" from the text. The current definition is the movement or mani1ulation of any l_

component within the reactor pressure vessel and continues with the requirement that j

the suspension of Core Alterations shall not preclude complet.on of movement of a component to a safe conservative position. This change is consistent with the

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recommendations of NUREG-1431, Rev.1.

Safety Evaluation The Specifications which use the definition of Core Alteration are those that protect from or mitigate a reactivity excursion event. - In keeping with this, the proposed 1

definition will not consider movement of components other than fuel, sources, or i

reactivity control components as Core Alterations. The movement of other components l

will have negligible (if any) affect on core reactivity. Therefore, there is no Technical Specification restriction on the movement of components other than fuel, sources, and reactivity control components. Plant administrative controls will control the movement

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of components other than fusi, sources, and reactivity control components within the reactor vessel.

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The current Technical Specifications provide the allowance that suspension of Core i

Alteration shall not preclude completion of movement of a component to a safe conservative position. The proposed change will delete the word " conservative" from the allowance and will allow fuel to be moved to a " safe" position. When Core Alterations are required to be suspended, a specific movement may have to be completed in order to establish a " safe" configuration (e.g., no fuel assembly j

suspended from the refueling machine). The requirement to establish a " safe" position is deemed proper. Eliminating the requirement to also be in a " conservative" position avoids potential confusion since there is no reference on which to base the j

conservative evaluation. It is assumed that " conservative"is intended to reflect the same context as " safe." This proposed change is acceptable since

  • safe" adequately

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controls the requirement to complete the move.

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Docum3'nt Control Desk l

Attachment ll TSP 970003 RC-97-0064 j

Page 2 of 2 i

The current Technical Specification utilizes the terms " movement or manipulation" of,.

in the definition of Core Aheration. This change will delete the terms "or manipulation" from the definition. The term " manipulation" is redundant with " movement" because, in order to manipulate components within the vessel, " movement" is necessary.

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Document Contrcl Desk

  • 11 i

TSP 970003 l

RC-97-0064 Page 1 of 3 NO SIGNIFICANT HAZARDS EVALUATION FOR REVISING THE DEFINITION FOR CORE ALTERATION IN THE VIRGIL C. SUMMER NUCLEAR STATION I

TECetNICAL SPECIFICATIONS Description of Amendment Reauest t

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The Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS) are being l

revised to change the definition of Core Alteration to be the movw. ant of fuel, sources, or reactivity control components; and to delete "or manipulation" and " conservative" from the text. The current definition is the movement or manipulation of any component within the reactor pressure vessel, and the definition continues with the requirement that the suspension of Core Alterations shall not preclude completion of i

movement of a component to a safe conservative position. This change is consistent l

with the recommendations of NUREG-1431, Rev.1.

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Basis for No Sianificance Hazards Consideration Determination l

South Carolina Electric & Gas Company (SCE&G) has evaluated the proposed changes to the VCSNS TS described above against the Significant Hazards Criteria of 10 CFR 50.92 and has determined that the changes do not involve any significant j

hazard. The following is provided in support of this conclusion.

1.

Does the change involve a significant increase in the probability or j

consequences of an accdent previously evaluated?

The proposed changes revise the definition of Core Alteration to be the movement of fuel, sources, or reactivity control components; and to delete "or manipulation" and " conservative" from the text. These changes do not affect the probability of an accdont previously evaluated. The movement of 4

j components other than fuel, sources, and reactivity control components, within the reactor vessel is enveloped by the analyzed event. Deleting the words "or manipulation" and " conservative" from the definition of Core Alteration are j

administrative changes and also do not impact initiators of analyzed events.

The only component assumed to be an initiator of an analyzed event is dropping an irradiated fuel assembly, however, fuelis still part of the definition.

j Furthermore, a fuel handling accident is minimized by administrative controls and physical limitations imposed on fuel handling operations. The movement of components other than fuel, sources, and reactivity control components within the reactor vessel will be controlled under plant administrative controls.

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4 Document Control DGsk Attachment lil TSP 970003 RC-97-0064 Page 2 of 3 This change has no effect on the boron dilution event because when boron concentration is below limits, Core Alterations are restricted to maintain the l

maximum Shutdown Margin. Movement of other components will have a negligible impact on core reactivity.

The changes to the definition of Core Alteration do not increase the consequences of an accident previously evaluated. The accident analysis assumes an irradiated fuel assembly is dropped with the consequences well within the 10 CFR 100 limits. The dropping of other components was not addressed in the plant safety analyses, however, the analysis of the dropped fuel assembly encompasses other components. The consequences of a boron dilution event are not addressed because Core Alterations are not allowed when i

the boron concentration is below limits. These changes do not affect the mitigation capabilities of any component or system nor do they affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a significant increase in the probability or

'l consequences of an accident previously evaluated.

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2.

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

The proposed changes revise the definition of Core Alteration to be the movement of fuel, sources, or reactivity control components; and to delete "or manipulation" and " conservative" from the text. The change does not involve a l

significant change in the design or operation of the plant. The changes do not involve a physical alteration of the plant (no new or dfferent type of equipment will be installed), or new or unusual operator actions. The changes will not impose any new or different requirements or eliminate any existing requirements. The definition of Core Alteration is being clarified and made consistent with NUREG 1431, Rev.1. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does this change involve a significant reduction in margin of safety?

The proposed changes revise the definition of Core Alteration to be the movement of fuel, sources, or reactivity control components; and to delete "or manipulation" and " conservative" from the text. The safety analysis assumes an irradiated fuel assembly is dropped Controls for handling components other than fuel, sources, or reactivity control components within the reactor vessel are in plant administrative controls. The effect of a boron dilution event on Shutdown Margin is limited due to the requirement to suspend Core Alterations.

The movement of other components have a negligible impact on core reactivity.

No change is being proposed, in the applicability of the definition, to the

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' Document Control Desk j

Attachment lli TSP 970003 i

RC-97-0064 4

Page 3 of 3 i

4 movement of components which factor in the design basis analyses (fuel handling accident). Deleting the terms "or manipulation" and " conservative" from the definition of Core Alteration results in a clarification to the definition that l

does not technically alter the meaning. Therefore, the change does not involve a significant reduction in a margin of safety l

l Pursuant to 10 CFR 50.91, the peceding analyses provides a determination that the

. proposed Technical Specificciions che.cge poses no significant hazard as delineated by 10 CFR 50.92.

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j Environmental Assessment x

i This proposed Technical Specification change has been evalua'd against criteria for l

and identification of licensing and regulatory actions requiring environmental i

assessment in accordance with 10 CFR 51.21. It has been determined that the proposed change meets the criteria for categorical exclusion as provided for under 10 i

i CFR 51.22(c)(9). The following is a discussion of how the proposed Technical l

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Specification change meets the criteria for categorical exclusion.

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10 CFR 51.22(c)(9): Although the proposed change involves change to a definition, (i) the proposed change involves No Significance Hazards Consideration (refer to the No Significance Hazards Consideration Determination section of this j

Technical Specification Change Request);

i (ii) there are no significant changes in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed i

changs does not affect the generation of any radioactive effluents nor does it affect any of the permitted release paths; and s

i (iii) there is no significant increase in indvidual or cumulative occupational radiation exposure.

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Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Bami cn the aforementioned and pursuant to 10 CFR i

I 51.22 (b), no environmental asses'; ment or environmentalimpact statement need be prepared in connection with issua1ce of an amondment to the Technical Specification

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incorporating the proposed chango of this request.

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