ML20196D676

Proposed Tech Specs LCO 3.9.3,allowing Both Doors in Personnel Air Locks & Single Door in Oeh to Be Open During Refueling Operations

ML20196D676
Person / Time
Site:	Crystal River
Issue date:	11/30/1998
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20196D674	List: 3F1198-06, LAR 244,rev 0,for License DPR-72,proposing Changes to Improved TS LCO 3.9.3 to Allow Both Doors in Personnel Air Locks & Single Door in Oeh to Be Open During Refueling Operations ML20196D676
References
NUDOCS 9812020306
Download: ML20196D676 (13)

Text

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

~

a. The equipment hatch eksed 5E66taiiTeiidfpiisit7hiEli 10EHE.insfallid and held in place by four bolts; 1

l

'b. FiiihTNUsP6f eine door'in each air lock liisd7We'd66E3ii khe10EHWfdasG1 Tidy c1osedE6EHiisbleioft:be'ing

$1osedibygdesignatedliiidiEidua]headilyiavailablii.36 Close dheloperGdoot; and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent. These penetrations may be open provided the total calculated flow rate out of the open penetration (s) is less than or equal to the equivalent flow rate through a 48 inch '

containment purge line penetration; or

2. capable of being closed by an OPERABLE containment purge or mini-purge valve.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME  ;

l A. One or more A.1 Suspend CORE 1mmediately containment ALTERATIONS.

penetrations not in required Status.

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

m 9812020306 PDR ADOCK O 981130g2(- t p -

Crystal River Unit 3 3.9-4 Amendment No.

I

. _ _ _ _ _ _ _ _ . . _ __ _._ _ _ _ . _ _ _ _ _ _ _ _ _ . _ ~

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations l

BASES I i

k BACKGROUND An accident which occurs during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment will have  !

any released radioactivity i estricted liiffid from escaping  !

to the environment. In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, the requirement to isolate the containment from the outside atmosphere is less stringent

than those established for MODES 1 through 4. In order to  !

4 make this distinction, the penetration requirements are '

referred to as " containment closure" rather than i " containment OPERABILITY." Containment closure means that i all potential escape paths for radioactivity are closed or capable of being closed.

i The containment equipment hatch hirJitiiisMiifisiifDiiidW '

4 10ENT provides a means for moving large equipment and components into and out of containment. During CORE  ;

ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch 6E9EM must be held in 4 place by at least four bolts. The required number of bolts ,

is based on dead weight and is acceptable due to the low i likelihood of a pressurization event. Good engineering l practice dictates that the bolts required by this LCO be tpp~roximately egually spaced. fMinfCORE7ALTERATIOWsr

movemistT6fBiraiHitedifis1?sifisinb11es leithin icontainmend

'ontainmenticlosepe)is? required;)therefosehtheTdoorMnEthi c

1 OEM {1fsinsta11edhfeestialwaysiremainiclosedforibelcapable bEbeing1 closed! i I

i

The containment air locks provide a means for personnel l access during MODES 1, 2, 3, and 4 in accordance with o LCO 3.6.2, " Containment Air Locks." Each air lock has a

! door at both ends. The doors are normally interlocked to l prevent simultaneous opening when containment OPERABILITY is j required. However, during periods of unit shutdown when containment OPERABILITY is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment ingress and egress is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air 1ock door must always remain c1osed pKbs5EipidsliIbf26eini R)iisd. l l

i (continued)

Crystal River Unit 3 8 3.9-9 Amendment No.

l

2' l Containment Penetrations i B 3.9.3 BASES

\

l BACKCROUND If3h~5?d66EiiFtE0EGiffihssll'idT6F7tsth?id56"r~s31h"Eh'e' (continued) icontainmentiai rdockssare "opendent contai nmenti closure 3 s required, eaMesignated Lindividuah suht: bef readilyf availabli I

. to close;the doodintthe-OEH!and?atileast!one doorMnfeach ai slockM0perations ! p' ersonnel s di rectl yli nvolved fin

' refueling? operations /shallt beiawarnfofa thetidentity 6fTdii l d  !

' esignatedlindividual(s)MThe?

ishallfremain?within? desionated; individual sufficientTproxlmity/tosthe (s)6Fs

'open)do  ;

totassisttin7evacuationVof personnelsinsideTcontainment;and  !

, ko(closekthelopenCdoot(s)lasisooCasievacuationsis '

, completed 2 l

a i

The requirements on containment penetration closure ensure l that a release of fission product radioactivity within td thCEnik6pmehfiffdsZthii containment will be restricted from

escaping to the envircament U mhed. The closure restrictions are sufficient to restnet limit fission l J

product radioactivity release from containment due to a fuel handling accident during refueling. 1 In MODE 6, it is necessary to periodically recirculate /

exchange RB atmosphere in order to minimize radiation uptake  !

during the conduct of refueling operations. The 48 inch purge valves are normally used for this purpose, but the  !

mini-purge valves may be relied upon as well. Both valve 1 types are automatically isolated on a unit vent-high radiation signal (from RMA-1). So long as one valve in the 4 flow path is OPERABLE, these lines may remain unisolated during the subject plant conditions.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated by a minimum of one isolation device.

Isolation may be achieved by an automatic or manual isolation valve, blind flange, or equivalent. Equivalent isolation methods include use of a material (e.g., temporary sealant) that can provide a temporary, atmospheric pressure ventilation barrier for the other containment penetrations during fuel movements.

These penetrations may be open provided the total calculated flow rate out the open penetrations is less than or equal to the equivalent flow rate through a 48 inch containment purge line penetration. This allowance is consistent with the CR-3 fuel handling accident inside the reactor building. The licensing basis analysis assumed a puff release of radionuclides from the RB following the FHA event. No credit was taken for the RB purge filters. Limiting the flow rate out the open penetrations to a flow rate less than or equal to the flow rate through the RB purge system is reasonable and conservative, given the plant licensing basis. Offsite doses from this analysis were well within 10 CFR 100 limits. Thus, the GR-3 fuel-handHng accident analysis dose picjections are t,cunded se long-as the leakage frooi the RO is less than-the acminal RC purge-ficw rate.

With the containment purge valves OPERABLE, no leakags value has to be assigned to these penetrations, and the entire (continued)

Crystal River Unit 3 B 3.9-10 Amendment No.

. - . .. - - . -. -. . - . = - - .- _.

e Containment Penetrations i B 3.9.3

] BASES BACKGROUND 50,000 cfm can be allocated to other penetrations providing (continued) direct access. With the containment purge valves inoperable,

• these va Ives are allowed to be open during the Applicability of thit Specification, however; no additional penetrations are allowed to be un-isolated during this time.

APPLICABLE During CORE ALTERATIONS or movement of fuel assemblies SAFETY ANALYSES within containment with irradiated fuel in containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, " Refueling Canal Water Level," the administrative limit on minimum decay time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the movement of irradiated fuel in the vessel, and this LCO ensure that the release of fission product radioactivity subsequent to a fuel handling accident results in doses that are within the requirements specified in 10 CFR 100.

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement. '

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity from containment. The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be .

closed 6EdibabRi61EtisidiTdl6Teid except for penetrations contair.ing an OPERABLE purge or mini-purge valve. F6FJths "cbstilissenChiFlI16Eki~ind th_eTOEHi(ifdnstillsdEboth?do6Fs p nitka1 R1ocks L and %he?doorlindheiOEH yayJe : openi.onli underiadmiiitstrativelcontrolsi For the containment purge and mini-purge valves to be considered OPERABLE, these valves (penetrations) must be automatically isolable on a unit vent-high radiation isolation signal.

The definition of " direct access from the containment atmosphere to the outside atmosphere" is any path that would allow for transport of containment atmosphere to any atmosphere located outside the containment structure. This includes the Auxiliary Building. As a general rule, closed or pressurized systems do not constitute a direct path (continued)

Crystal River Unit 3 8 3.9-11 Amendment No.

Containm:nt Panstrations B 3.9.3 BASES LCO between the RB and outside environments. All permanent and (continued) temporary penetration closures should be evaluated to assess the possibility for a release path to the outside ,

environment. For the purpose of determining what constitutes a " direct access" path, no failure mechanisms should be applied to create a scenario which results in a ,

" direct access" path. For example, line breaks, valve '

failures, power losses or natural phenomenon should not be l postulated as part of the evaluation process.

These penetrations may be open provided the total calculated

, flow rate out the open penetrations is less than or equal to the equivalent flow rate through a 48 inch containment purge line penetration. The CR-3 fuel handling accident analysis dose projections are bounded 30 long as the leakage froiii the RO is less than this ficw rate.

APPLICABILITY The containment penetration requirements are applicable

,. during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is the period of

highest risk potential for a fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1, " Containment." When CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

ACTIONS A.1 and A.2 With the containment equipment hatch, Did7 air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere not in the required status, including fiilsFelsMaplessiffTequlFid n~d miiiiiWat19dic6nfr61i3~riopen;0EH3andiairilocksdoorsliiid the containment purge or mini-purge valve penetrations not capable of automatic isolation when the penetrations are unisolated, the plant must be placed in a condition in which the isolation function is not (continued)

Crystal River Unit 3 8 3.9-12 Amendment No.

Containment Penetrations B 3.9.3 l

BASES ACTIONS A.1 and A.2 (continued)

! needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies a

within containment. Performance of these actions shall not

! preclude moving a component to a safe position.

SURVEILLANCE 58__M.dd REQUIREMENTS This Surseillance demonstrates that each of the containment penetrations required to be in its closed position is in that position 7andTtEt75dsiilidifWi7EdstFolsffi4diFid"f66 l 5psilOEHIE6dlairljock!doori.artsbeingtimplemented.

l The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irradiated fuel assemblies within the containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. As such, this Surveillance ensures that a pcstulated fuel handling accider,t that releases fissica picduct radioactivity within the contair, ment will not result in a release of fissicr. product radioactivity to the envircamaat.

SR 3.9.3.2 This Surveillance demonstrates that each containment purge and mini-purge valve actuates to its isolation position on an actual or simulated high radiation signal. The 24 month Frequency is consistent with other similar instrumentation and valve testing requirements. The Surveillance ensures that the valves are capable of closing after a postulated fuel handling accident to limit a release of fission product radioactivity from the containment. SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. l REFERENCES 1. FSAR, Section 14.2.2.3.

l 1

l I

l Crystal River Unit 3 B 3.9-13 Amendment No.

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 i

ATTACIIMENT C l LICENSE AMENDMENT REQUEST #244 REVISION 0 ,

l I

Proposed ITS and ITS Bases.  ;

i Change Pages - Revision Bars l

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n

(

l w.

Containm:nt Penetrations 3.9.3

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

a. The equipment hatch or outage equipment hatch (OEH) installed and held in place by four bolts,

b. A minimum of one door in each air lock and the door in the OEH (if installed) closed, or capable of being closed by a designated individual readily available to close the open door; and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent. These penetrations may be open provided the total calculated flow rate out of the open penetration (s) is less than or equal to the equivalent flow rate through a 48 inch containment purge line penetration; or

2. capable of being closed by an OPERABLE containment purge or mini-purge valve.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One o. more A.1 Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status.

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

Crystal River Unit 3 3.9-4 Amendment No.

I Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS l

B 3.9.3 Containment Penetrations BASES i

~

BACKCROUND An accident which occurs during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment will have any released radioactivity limited from escaping to the l environment. In MODE 6, the potential for containment i pressurization as a result of an accident is not likely; therefore, the requirement to isolate the containment from the outside atmosphere is less stringent than those i established for MODES 1 through 4. In order to make this distinction, the penetration requirements are referred to as

" containment closured rather than " containment OPERABILITY."

Containment closure means that all potential escape paths l for radioactivity are closed or capable of being closed. j The containment equipment hatch or outage equipment hatch  !

(OEH) provides a means for moving large equipment and I

components into and out of containment. During CORE ALTERATIONS or movement of irradiated fuel assemblies within  !

containment, the equipment hatch or OEH must be held in l l place by at least four bolts. The required number of bolts  !

is based on dead weight and is acceptable due to the low '

likelihood of a pressurization event. Good engineering practice dictates that the bolts required by this LCO be '  ;

approximately equally spaced. During CORE ALTERATIONS or >

movement of irradiated fuel assemblies within containment, i containment closure is required; therefore, the door in the OEH (if installed) must always remain closed or be capable of being closed.

The containment air locks provide a means for personnel access during MODES 1, 2, 3, and 4 in accordance with LCO 3.6.2, " Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. However, during periods of unit shutdown when containment OPERABILITY is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment ingress and egress is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed or be capable of being closed.

(continued)

Crystal River Unit 3 8 3.9-9 Amendment No.

. I Containmtnt Penetrations B 3.9.3 BASES BACKGROUND If the door in the OEH (if installed) or both doors in the (continued) containment air locks are open when containment closure is required, a designated individual must be readily available to close the door in the OEH and at least one door in each air lock. Operations personnel directly involved in refueling operations shall be aware of the identity of the

, designated individual (s). The designated individual (s) ,

J shall remain within sufficient proximity to the open doors to assist in evacuation of personnel inside containment and to close the open door (s) as soon as evacuation is completed.

The requirements on containment penetration closure ensure that a release of fission product radioactivity to the environment from the containment will be limited. The closure restrictions are sufficient to limit fission product radioactivity release from containment due to a fuel handling accident during refueling.

In MODE 6, it is necessary to periodically recirculate /

exchange RB atmosphere in order to minimize radiation uptake during the conduct of refueling operations. The 48 inch purge valves are normally used for this purpose, but the mini-purge valves may be relied upon as well. Both valve types are automatically isolated on a unit vent-high radiation signal (from RMA-1). So long as one valve in the flow path is OPERABLE, these lines may remain unisolated during the subject plant conditions. 1 The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated by a minimum of one isolation device.

Isolation may be achieved by an automatic or manual isolation valve, blind flange, or equivalent. Equivalent isolation methods include use of a material (e.g., temporary sealant) that can provide a temporary, atmospheric pressure ventilation barrier for the other containment penetrations during fuel movements.

These penetrations may be open provided the total calculated flow rate out the open penetrations is less than or equal to the equivalent flow rate through a 48 inch containment purge line penetration. This allowance is consistent with the CR-3 fuel handling accident inside the reactor building. The licensing basis analysis assumed a puff release of radionuclides from the RB following the FHA event. No credit was taken for the RB purge filters. Limiting the flow rate out the open penetrations to a flow rate less than or equal to the flow rate through the RB purge system is reasonable and conservative, given the plar.t licensing basis. Offsite doses from this analysis were well within 10 CFR 100 limits. With the containment purge valves OPERABLE, l no leakage.value has to be assigned to these penetrations, and the entire (continued)

Crystal River Unit 3 B 3.9-10 Amendment No.

Containment Penetrations B 3.9.3 BASES BACKGROUND 50,000 cfm can be allocated to other penetrations providing (continued) direct access. With the containment purge valves inoperable, these valves are allowed to be open during the Applicability of this Specification, however; no additional penetrations are allowed to be un-isolated during this time.

APPLICABLE During CORE ALTERATIONS or movement of fuel assemblies SAFETY ANALYSES within containment with irradiated fuel in containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, " Refueling Canal Water Level," the administrative limit on minimum decay time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the movement of irradiated fuel in the vessel, and this LCO ensure that the release of fission product radioactivity subsequent to a fuel handling accident results in doses that are within the requirements specified in 10 CFR 100.

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement.

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity from containment. The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed or capable of being closed except for penetrations containing an OPERABLE purge or mini-purge valve. For the containment air locks and the OEH (if installed), both doors in the air locks and the door in the OEH may be open only under administrative controls. For the containment purge and mini-purge valves to be considered OPERABLE, these l valves (penetrations) must be automatically isolable on a l unit vent-high radiation isolation signal.

The definition of " direct access from the containment atmosphere to the outside atmosphere" is any path that would allow for transport of containment atmosphere to any atmosphere located outside the containment structure. This includes the Auxiliary Building. As a general rule, closed or pressurized systems do not constitute a direct path (continued)

Crystal River Unit 3 B 3.9-11 Amendment No.

Containm:nt Penetrations B 3.9.3 BASES LCO between the RB and outside environments. All permanent and (continued) temporary penetration closures should be evaluated to assess the possibility for a release path to the outside environment. For the purpose of determining what constitutes a " direct access" path, no failure mechanisms should be applied to create a scenario which results in a

" direct access" path. For example, line breaks, valve failurcs, power losses or natural phenomenon should not be postulated as part of the evaluation process.

These penetrations may be open provided the total calculated flow rate out the open penetrations is less than or equal to the equivalent flow rate through a 48 inch containment purge line penetration. l APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is the period of highest risk potential for a fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1, " Containment." When CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

ACTIONS A.1 and A.2 With the containment equipment hatch, OEH, air locks, or any l containment penetration that provides direct access from the containment atmosphere to the outside atmosphere not in the required status, including failure to implement required 1 administrative controls for open OEH and air lock doors and I the containment purge or mini-purge valve penetrations not capable of automatic isolation when the penetrations are unisolated, the plant must be placed in a condition in which i the isolation function is not 1

i (continued)

Crystal Rive- Unit 3 B 3.9-12 Amendment No.

I Containment Penetrations B 3.9.3 BASES ACTIONS A.1 and A.2 (continued) needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude moving a component to a safe position.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position, and that administrative controls required for open OEH and air lock doors are being implemented.

The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irradiated fuel assemblies within the containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. l SR 3.9.3.2 This Surveillance demonstrates that each containment purge and mini-purge valve actuates to its isolation position on an actual or simulated high radiation signal. The 24 month Frequency is consistent with other similar instrumentation and valve testing requirements. The Surveillance ensures that the valves are capable of closing after a postulated fuel handling accident to limit a release of fission product radioactivity from the containment. SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements.

l REFERENCES 1. FSAR, Section 14.2.2.3.

I I

Crystal River Unit 3 B 3.9-13 Amendment No.