Text

Proposed Tech Specs Revising TS Associated with Various Esfss Which Need No Longer Be Credited Following Design Basis Fuel Handling Accident
	ML20196G713
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Site:	Grand Gulf
Issue date:	06/23/1999
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,

Primtry Containment and Drywell Isolation Instrumentation i

3.3.t.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I

J.

(continued)

J.3.1 Initiate action to Immediately restore secondary containment to OPERABLE status.

1 J.3.2 Initiate action to Immediately restore one standby gas treatment (SGT)

I subsystem to OPERABLE l

status.

AN.Q J 3.3 Initiate action to Immediately restore isolation capability in each required secondary containment penetration flow path not isolated.

I i

l K.

As required by K.1 Isolate the affected Immediately Required Action C.1 penetration flow and referenced in path (s).

Table 3.3.6.1-1.

l 0E Q,..diaic(

K.2.1

pr.d 20R E EAAueNS.

-8!!E-l K.E.2 Suspend movement of Immediately i

l irradiated fuel (6 cmp /

assemblies in the l

primary and secondary 4

containment.

AND

^

(continued)-

GRAND GULF 3.3-51 Amendment No. 120 9007010251 990623 PDR ADOCK 05000416 P

PDR

i Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 i

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME K.

(continued)

K.2.)

Initiate action to Immediately i

suspend operations with a potential for draining the reactor vessel.

)

4 GRAND GULF 3.3-52 Amendment No. 120

~

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1 1 (page 2 of 5)

Primary Contatrinent and Drywell Isolation Instrunentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM sPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWA8LE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE 2.

Primary Containment and Drywell leolation (continued) b.

Drywell Pressure - High 1,2,3 2(D)

H SR 3.3.6.1.1 5 1,43 psig SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6

$4 3.3.6.1.7 c.

Reactnr vessel Water 1,2,3 2(b)

F st 3.3.6.1.1 2 152.5 Level - Low Low Low, SR 3.3.6.1.2 inches Level 1 (ECCs SR 3.3.6.1.3 Divinf or.s 1 and 2) st 3.3.6.1.6 st 3.3.6.1.7 d.

Drywet t Pressure - High 1,2,3 2

F st 3.3.6.1.1 5 1.44 pels (ECCS Divisione 1 st 3.3.6.1.2 and 2) st 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 e.

Reactor Vessel Water 1,2,3 4

F st 3.3.6.1.1 t 43.8 Level - Low Low, Level st 3.3.6.1.2 inches 2 (MPCs)

$R 3.3.6.1.3 SR 3.3.6.1.6 st 3.3.6.1.7 f.

DryweL L Pressure - High 1,2,3 4

F st 3.3.6.1.1 s 1.44 psig (HPCs) st 3.3.6.1.2 st 3.3.6.1.3 sa 3.3.6.1.6 st 3.3.6.1.7 g.

Containment and Drywell 1,2,3 2(b)

F SR 3.3.6.1.1 5 4.0 mR/hr Ventilation Exhaust SR 3.3.6.1.2 Radiation - Migh SR 3.3.6.1.5 SR 3.3.6.1.7 (c) 2 K

st 3.3.6.1.1 s 4.0 set /hr SR 3.3.6.1.2 st 3.3.6.1.5 SR 3.3.6.1.7 h.

Manual Initiation 1,2,3 2(b)

G st 3.3.6.1.7 NA (c) 2 G

st 3.3.6.1.7 NA (continued)

(b) Also required to initlete the associated drywell isolation furstion.

(c) DuringCr r:=;eQ movenient o irradiated fuel assembtles in primary or secondary contairemen and operations witn a potential for raining the reactor vessel.

recentj GRAND GULF 3.3-55 Amendment No. 120

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2 1 (page 1 of 1) secondary Contaltnent Isolation Instrumentation APPLICA8LE MODES AND REQUIRED OfMER CHANNELS SPECIFIED PER TRIP suRVE!LLANCE ALLOWAgLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE 1.

Reactor Vessel Water 1,2,3,(e) 2 sa 3.3.6.2.1 2 43.8 inches Level - Low Low, Level 2 SR 3.3.6.2.2 SA 3.3.6.2.3 st 3.3.6.2.5 SR 3.3.6.2.6 2.

Drywell Pressure - High 1,2,3 2

sa 3.3.6.2.1 s 1.43 psig SR 3.3.6.2.2 st 3.3.6.2.3 st 3.3.6.2.5 SR 3.3.6.2.6 3.

Fuel Handling Aree 1,2,3, 2

SR 3.3.6.2.1 s 4.0 m/hr Ventilation Exhauet (e),(b) sa 3.3.6.2.2 Radiation-Nigh High SR 3.3.6.2.4 st 3.3.6.2.6 SR 3.3.6.2.7 4.

Fuel Handling Aree Pool 1,2,3, 2

sa 3.3.6.2.1 s 35 aft /hr sweep Exhaust (a),(b) sa 3.3.6.2.2 Radiation - Nish High SR 3.3.6.2.4 st 3.3.6.2.6 SR 3.3.6.2.7 5.

Manuel Initiation 1,2,3, 2

sa 3.3,6.2.6 NA (s),(b) 1 (a) During operulone with a potential for dretning the reactor vessel.

(b) During 4?:S?:20rd_l} movement Irradiated fuel assemblies in the primary or secondary contei, -,..

ceceritly GRAND GULF 3.3-62 Amendment No. 120

PCIVs l

3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and E.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, AND B, C, or D not met in MODE 1, 2, or 3.

E.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F.

Required Action and F.1

NOTE---------

associated Completion LC0 3.0.3 is not Time of Condition A, applicable.

B, C, or D not met for PCIV(s) required to be OPERABLE during Suspend movement of Immediately pec,grdfy}1 movementohirradiated irradiated fuel fuel assemblies in assemblies in primary the primary or and secondary t

secondary c tainment.

containment.

g/

G.

Required Action and G.1 Suspend CORE lrdietMy associated Completto

" ALTERATIONS.

Time of Conditi B, C, or D met for PC s) required to OPERABLE during C E ALTERATIONS.

G h*

Required Action and Initiate action to Immediately associated Completion suspend OPDRVs.

Time of Condition A, B, C, or D not met for 0_R PCIV(s) required to be OPERABLE during MODE 4

.2 Initiate action to Immediately or.5 or during restore valve (s) to operations with a OPERABLE S'ATU.S.

potential for draining b

the reactor vessel (OPDRVs).

GRAND GULF 3.6-13 Amendment No. 120

rT,.

seconaa-m :nment C 4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of rradiated fuel assemblies in the primary n

or secondary containment, Tuu.la3 COR: "' TE"'T:0"C )

During operations witn a potential for draining the reactor vessel (0PDRVs).

ACTIONS CONDITION REQUIRED ACTION CMPLETION TIME A.

Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, containment to 2, or 3.

OPERABLE status.

B.

Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

GRAND GULF 3.6-42 Amendment No. 120

p.

Secondary Containment a

3.6.4.1 ACTIONS (continued) l l

CONDITION REQUIRED ACTION COMPLETION TIME C.

Secondary C.1

NOTE---------

containment LCO 3.0.3 is not inoperable during applicable, mo ment ofwirradiated uel assemblies in the I rCCenY rec 6MIfY primary or secondary pend movement of Immediately

- ? 40ntainnentfduri irradiated fuel ec":. f,L"EPF IN t,or assemblies in the during OPDRVs.

primary and secondary containment.

AND 4 -- "

'--d'""] h

^"r C.2 f ;,;;;;';;,"; j g

'----'u Q. m.,,,.....,

-.R h

Immediatep nitiate action to uspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all auxiliary building and 31 days enclosure building equipment hatches and blowout panels are closed and sealed.

SR 3.6.4.1.2' Verify each auxiliary building and 31 days enclosure building access door is closed, except when the access opening is being used for entry and exit.

(continued) i l

GRAND GULF 3.6-43 Amendment No. 120

II, l

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LC0 3.6.4.2 Each SCIV shall be OPERABLE.

r6 C.ENIf APPLICABILITY:

MODES 1, 2, and 3, r During movement oftirradiated fue assemblies in the primary

- nr secondary containment, E

hr',; C0Z ALTEDynu5]

)uring operations with a potential for draining the reactor vessel (0PDRVs).

ACTIONS i

.....................................N0TES------------------------------------

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths penetration flow path with one SCIV by use of at least inoperable.

one closed and de-activated automatic valve or damper, closed manual valve or damper, or blind fl ange.

AND (continued)

[

GRAND GULF 3.6-45 Amendment No. 120 l

l

r e

SCIVs l

3.6.4.2 ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and 0.1

NOTE---------

associated Completion LC0 3.0.3 is not Time of Condition A

o licable.

r8&f/

or B not met during k gnt;k- -----------------

/

movement ofMrradiated p

fuel assemblies in the Suspend movement of Immediately primary or secondary irradiated fuel contai nmentC;.r i- '

assemblies in the 5"";"LT=T!=,dr primary and secondary during OPDRVs.

containment.

AND D.2 y^".

- !.;...d : eteljj

~

y.........

D nitiate action to Immediately suspend OPDRVs.

I I

l r

l GRAND GULF 3.6-47 Amendment No. 120 l

l

d.

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement o rradiated fuel assemblies in the primary w _,_S,".,.lI3 N.onn.g n{ainment, J

Y

.... m,)

t.....

.~ m During operatiors with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable.

to OPERABLE status, B.

Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND not met in MODE 1, 2, or 3.

B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.

Required Action and

NOTE-------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not met during tecergflv movement oftirradiated C.1 Place OPERABLE SGT Immediately

/

fuel assemblies in the subsystem in primary or secondary operation.

OR during uruxys. -

(continued)

GRAND GULF 3.6-49 Amendment No. 120

f1, SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Cre centJI C.

(continued)

C.2.1 Suspend movement of Immediately irradiated fuel assemblies in the primary and secondary containment.

AND C.2.2

-Suspand CCP.E

,dicte!

j

..LTEP.^.T!0 5. f

^

ANO f

C...

Initiate action to Immediate1]

y suspend OPDRVs.

4 D.

Two SGT subsyster D.1 Enter LC0 3.0.3.

Immediately inoperable in MOD.1, 2, or 3.

E.

Two SGT subsystems E.1 Suspend movement of Immediately inoperable _during irradiated fuel q

movement ofh rradiated assemblies in the

[ggent)/v fuel assemblies in the primary and secondary y

primary or secon r

__ i containment.

cenflIl9l containment,-,. W a r

S 50"E "1 X ""TI^,4S., or during OPDR s,

--~- -- uj Q

/\\

g Initiate action to Immediately suspend OPDRVs.

m.-

GRAND GULF 3.6-50 Amendment No. 120 l

o l'4 Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE 2.c.

Reactor Vessel Water Level-Low low Low, level 1 SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY to the drywell are channeled to the suppression pool to maintain the pressure suppression function of the drywell.

Reactor vessel water level signals are iritiated from level transmitters that sense the difference between the pressure due to a constant colunin of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

Four channels of Reactor Vessel Water Level-Low Low Low, Level 1 Function are available and are required to be ODERABLE to ensure that no single instrument failure can preclude the isolation function.

The Reactor Vessel Water Level-Low Low Low, Level 1 Allowable Value is chosen to be the same as the ECCS Reactor Vessel Water Level-Low Low Low, Level 1 Allowable Value (LCO 3.3.5.1) to ensure the valves are isolated to prevent offsite doses from exceeding 10 CFR 100 limits.

This Function isolates the Group 5 isolation valves.

2.g.

Containment and Drvwell Ventilation Exhaust Radiation-Hioh High ventilation exhaust radiation is an indication of '

possible gross failure of the fuel cladding.

The release may have originated from the primary containment due to a break in the RCPB. When Exhaust Radiation-High is 1

detected, valves whose penetrations communicate with the primary containment atmosphere are isolated to limit the release of fission products.

In addition, this Function provides an isolation signal to certain drywell isolation valves. The isolation of drywell isolation valves, in combination with other accident mitigation systems, functions to ensure that steam and water releases to the drywell are channeled to the suppression pool to maintain-the pressure suppression function of the drywell. % TnsN -

The Exhaust Radiation-High signals are initiated from 33 E

radiation detectors that are located on the ventilation exhaust piping coming from the drywell and containment. The signal from each detector is input to an individual monitor whose trip outputs are assigned to an isolation channel.

(continued)

GRAND GULF B 3.3-147 Revision No. O

c..

l Proposed inserts to Bases for TS 3.3.6.1 j

L l

. lNSERT B 3.3-147A Additionally, the Ventilation Exhaust Radiation - High is assumed to initiate isolation of the i

, primary containment during a fuel handling accident involving the handling of recently irradiated j

fuel (Ref. 2).

1 n

{

INSERT B 3.3-148A J

1 Due to radioactive decay, this Function is only required to isolate primary containment during those fuel handling accidents involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days).

s

)

I Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE 2.o.

Containment and Drywell Ventilation Exhaust SAFETY ANALYSES, Radiation-HiQh (continued)

LCO, and

)

APPLICABILITY Four channels of Containment and Drywell Ventilation Exhaust-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

]

The Allowable Values are chosen to promptly detect gross failure of the fuel cladding and to ensure offsite doses remain below 10 CFR 20 and 10 CFR 100 limits.

The Function is required to be OPERABLE during ?

NITE"".T:^"!,) operations with a potential for drMg the reactor vessel (OPDRVsh end movement ofeirradiated fuel -

assembliesintheprimaryorsecondarycontainmentbecausedCgi the capability of detecting radiation releases due to fuel failures (due to fuel uncovery or dropped fuel assemblies) must be provided to ensure offsite dose limits are not

[

p.5VT exceededy 8 3 3 -IN These Functions isolate the Group 7 valves.

L 2.h.

Manual Initiation The Manual Initiation push button channels introduce signals into +.he primary containment and *drywell isolation logic that are redundant to the automatic protective instrumentation and provide manual isolation capability.

There is no specific UFSAR safety analysis that takes credit for this Function.

It is retained for the isolation function as required by the NRC in the plant licensing basis.

There are four push buttons for the logic, two manual initiation push buttons per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

Four channels of the Manual Initiation Function are available and are required to be OPERABLE.

(continued)

GRAND GULF B 3.3-148 Revision No. O

Primary Containment and Drywell Isolation Instrumentation

~

B 3.3.6.1 BASES ACTIONS J.1, J.2, J.3.1, J.3.2, and J.3.3 (continued I

associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability) in each secondary containment penetration flow path not isolated that is assumed to be isolated to mitigate radioactivity releases. This may be performed as an administrative check, by examining logs or other information, to determine if the components are out of service for maintenance or other reasons.

It is not necessary to perform the Surveillances needed to demonstrate

{

the OPERABILITY of the components.

If, however, any

(

required component is inoperable, then it must be restored to OPERABLE status.

In this case, the Surveillances may need to be performed to restore the component to OPERABLE status. Actions must continue until all required components are OPERABLE and K.1, K.2.1, K.2.2 G ".2. h If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the associated penetration flow path (s) should be isolated (Required Action K.1).

Isolating the affected penetration flow path (s) accomplishes the safety function of the inoperable instrumentation. Alternately, the plant must be placed in a 4 [ condition in which the LCO does not apply.C0Z ALTSATICL. 3 mov If applicable, must De immediately suspended. Suspension of these reCentLy activities shall not preclude completion of movement of a component to a safe condition. Also, if applicable, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission production release. Actions must continue until OPDRVs are suspended.

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each REQUIREMENTS Iso'1ation Instrumentation Function are found in the SRs column of Table 3.3.6.1-1.

The Surveillances are also modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided.the associated Function maintains (continued)

GRAND GULF B 3.3-167 Revision No. 0; cd HG(,

\\

Secondary Containment Isolation Instrumentation B 3.3.6.2

)

BASES APPLICABLE 3, 4.

Fuel Handling Area Ventilation and Pool Sweep Exhaust SAFETY ANALYSES, Radiation-High Hiah (continued)

LCO, and APPLICABILITY channels of Fuel Handling Area Ventilation Exhaust i

Radiation-High High Function and four channels of Fuel Handling Area Pool Sweep Exhaust Radiation-High High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The Allowable Values are chosen to promptly detect gross failure of the fuel cladding.

The Exhaust Radiation-High High Functions are required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists; thus, there is a probability of pipe breaks resulting in significant releases of radioactive steam and gas. In MODES 4 and 5, the probability and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES; thus, these Functions are not required.

In addition. the Functions are required to be OPERABLE duringE0oE 8E""='Q OPDRVsh and movement of irradiated fuel assemblies in the primary or secondary containment because the capability of detecting radiation releases due to fuel failures (due to fuel uncovery or MMtiy dropped fuel assemblies) must be provided to ensure that offsite dose limits are not exceeded.

//

Insert 5.

Manual Initiation gy,3.j-/g The Manual Initiation push button channels introduce signals into the secondary containment isolation logic that are redundant to the automatic protective instrumentation channels, and provide manual isolation capability. There is no specific UFSAR safety analysis that takes credit for this Function.

It is retained for the secondary containment isolation instrumentation as required by the NRC approved licensing basis.

There are four push buttons for the logic, two manual initiation push buttons per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

(continued)

GRAND GULF B 3.3-177 Revision No. O

Proposed inserts to Bases for TS 3.3.6.2 INSERT B 3.3-177A Due to radioactive decay, these Functions are only required to isolate secondary containment during those fuel handling accidents involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days).

e

l,

Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES APPLICABLE 5.

Manual Initiation (continued)

SAFETY ANALYSES, LCO, and Four channels of the Manual Initiation Function are APPLICABILITY available and age _reauired to_be_0PERABLE in MODES 1, 2, and 3 and during h mm wm. - ) OPDRV nd movement of irradiated fuel assemblies in the seconda ontainment,

~

rd.CerlilIU since these are the MODES and other specified conditions in which the Secondary Containment Isolation automatic Functions are required to be OPERABLE.

ACTIONS A Note has been provided to modify the ACTIONS related to secondary containment isolation instrumentation channels.

I Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, i

subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits 1

will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, l

with Completion Times based on initial entry into the l

Condition. However, the Required Actions for inoperable secondary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable secondary containment isolation instrumentation channel.

.A_d Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , depending on the Function, has been shown to be acceptable (Refs. 3 and 4) to permit restoration cf any inoperable channel to OPERABLE status.

Functions that share common instrumentation with the RPS have a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed out of service time consistent with the time provided for the associated RPS instrumentation channels. This out of

'I service time is only acceptable provided the associated Function is still maintaining isolation capability (refer to Required Action B.1 Bases).

If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the' channel must be placed in the tripped condition per Required Action A.I.

Placing the (continued)

GRAND GULF B 3.3-178 Revision No. O

PCIVs B 3.6.1.3 BASES (continued)

APPLICABLE The PCIVs LC0 was derived from the assumptions related SAFETY ANALYSES to minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during major accidents. As part of the primary contcinment boundary, PCIV OPERABILITY supports leak tightness of primary containment. Therefore, the safety analysis of any event requiring isolation of primary containment is applicable to this LCO.

The DBAs that result in a release of radioactive material for which the consequences are mitigated by PCIVs are a loss of coolant accident (LOCA), a main steam line break (MSLB),

and a fuel handling accidentsinside primary containment I

I k 634-158 {g (Refs.1 and 2).

L3u4 In the aialysis for each of these l

accidents, it is assumed that PCIVs are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through PCIVs are minimized. Of the events analyzed in Reference 1, the LOCA is the most i

limiting event due to radiological consequences. An

)

analysis of the affect of the purge valves being open at the initiation of a LOCA has been performed. This condition was found to result in dose contributions of a small fraction of 10 CFR 100.

It is assumed that the primary containment is isolated such that release of fission products to the environment is controlled.

PCIVs satisfy Criterion 3 of the NRC Policy Statement.

LC0 PCIVs form a part of the primary containment boundary and some also form a part of the RCPB. The PCIV safety function is related to minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during a DBA.

The power operated isolation valves are required to have isolation times within limits. Additionally, power operated automatic valves are required to actuate on an automatic isolation signal.

The normally closed PCIVs are considered OPERABLE when, as applicable, manual valves are closed or open in accordance with appropriate administrative controls, automatic valves are de-activated and secured in their closed position, or blind flanges are in place. The valves covered by this LC0 (continued)

GRAND GULF B 3.6-15 Revision No. O

1 r.

o

,o Proposed inserts to Bases of TS 3.6.1.3:

INSERT B 3.6-15A invoking the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days)

INSERT B 3.6-16A involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days)

A

PCIVs B 3.6.1.3 BASES LC0 are listed with their associated stroke times in the (continued) applicable plant procedures.

Purge valves with resilient seals, MSIVs, and hydrostatically tested valves must meet additional leakage rate requirements. Other PCIV leakage rates are addressed by LC0 3.6.1.1, " Primary Containment,"

as Type B or C testing.

This LC0 provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory, and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the prooability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE. Certain valves are required to be OPERABLE, however, to prevent a potential flow path (the RHR Shutdown Cooling System suction from the reactor vessel) from lowering reactor vessel level to the top of the fuel. These valves are those whose associated isolation instrumentation is required to be OPERABLE according to LC0 3.3.6.1,

" Primary Containment and Drywell Isolation Instrumentation,"

Function 5.b.

Additional valves are requirad to be OPERABLE to prevent release of radioactive material during a

, %A p_ostulated fuel handling accidents. These valves are those.

whose associated isolation instrumentation is required to be

'(O 3U OPERABLE according to LC0 3.3.6.1, " Function 2.g."

(This J

does not include the valves that isolate the associated instrumentation.)

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path (s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide (continued)

GRAND GULF B 3.6-16 Revision No. O

i PCIVs B 3.6.1.3

{

BASES ACTIONS D.1, 0.2, and 0.3 (continued) verification that those isolation devices outside primary containment and potentially capable of being mispositioned are in the correct position.

For the isolation devices inside primary containment, the time period specified as

" prior to entering MODE 2 or 3, from MODE 4 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For the primary containment purge valve with resilient seal that is isolated in accordance with Required Action D.1, SR 3.6.1.3.5 must be performed at least once every 92 days.

This provides assurance that degradation of the resilient j

seal is detected and confirms that the leakage rate of the primary containment purge valve does not increase during the time the penetration is isolated. The normal Fraquency for SR 3.6.1.3.5 is 184 days. Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR more often. Therefore, a Frequency of once per 92 days was chosen and has been shown acceptable based on operati7g experience.

I E.1 and E.2 If any Required Action and associated Completion Time cannot be met in 40DE 1, 2, or 3, the plant must be brought to a MODE in w..*rh the LC0 does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 sys ems.

G F.1. G.1, and If any Required Action and associated Completion Time cannot be met, the plant must be placed in a conditioi_in which the LC0 does not apply.

If applicable, CCCRE ^LTGATIOZ =O -

movement of irradiatad fuel assemblies in the primary and m

(continued)

GRAND GULF B 3.6-20 Revision No. 0

PCIVs B 3.6.1.3 i

BASES ACTIONS F.1, G.I.

)and (continued) secondary containment must be immediately suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe condition. Also, if applicable, action must be immediately initiated to suspend operations with a potential for draining the reactor vessel (0PDRVs) to minimize the probability of a vessel draindown and subsequent potential for fission product release.

Actions must continue until OPDRVs are suspended.

If suspending the OPDRVs would result in closing the residual heat removal (RHR) shutdown cooling" isolation valves, an alternative Required Action is provided to immediately initiate action to restore the valves to OPERABLE status.

This allows RHR to remain in service while actions are being taken to restore the valve.

SURVEILLANCE SR 3.6.1.3,,1 REQUIREMENTS This SR verifies thr:t the 20 inch primary containment purge valves are closed as required or, if open, open for an allowable reason.

If a purge valve is open in violation of this SR, the valve is considered inoperable.

If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakagg j outside of the limits The SR is also modified by a Note (Note 1) stating that primary containment purge valves are only required to be closed in MODES 1, 2, and 3.

At times other than MODE 1, 2, or 3 when the purge valves are required to be capable of closing (e.g., during movement of, irradiated fuel recef>tb assemblies) pressurization concerns are not present an

/

purge valves are allowed to be open (automatic isolation capability would be required by SR 3.6.1.3.4 and SR 3.6.1.3.7).

The SR is modified by a Note (Note 2) stating that the SR is not required to be met when the purge valves are open for the stated reasons. The Note states that these valves may be opened for pressure control, ALARA, or air quality considerations for personnel entry, or for Surveillances, or special testing of the purge system that require the valves to be open (e.g., testing of the containment and drywell ventilation radiation monitors). These primary containment (continued)

GRAND GULF B 3.6-21 Revision No. O

~

PCIVs B 3.6.1.3 BASES 1

1 SURVEILLANCE SR 3.6.1.3.5 (continued)

REQUIREMENTS primary containment and the environment), a Frequency of l

184 days was established. Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened).

Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

The SR is modified by a Note stating that the primary containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3.

If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times when the purge valves are required to be capable of closing (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

recentiv SR 3.6.1.3.6

/

Verifying that the ftl1 closure isolation time of each SiV is within the specified limits is required to demonstrate OPERABILITY. The full closure isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses.

The Frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6.1.3.7 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlaps this SR to provide complete testing of the safety function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating (continued)

GRAND GULF B 3.6-24 Revision No. O

)

Secondary Containment B 3.6.4.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.4.1 Secondary Containment BASES

' BACKGROUND The function of the secondary containment is to contain, dilute, and hold up fission products that may leak from primary containment following a Design Basis Accident (DBA).

'In conjunction with operation of the Standby Gas Treatment (SGT) System and closure of certain valves-whose lines

]

penetrate the' secondary containment, the secondary

{

containment is designed to reduce the activity level of the fission products prior to release to the environment and to isolate and contain fission products that are released-during certain operations that take place inside primary containment (e.g., during operations with a notential for g [ h aina the reactor vessel (OPDRVs)f t t ; 2"E] 'n

^' TE"^TF=Q or during movement ofdrractated fuel

-assemDlies in the primary or secondary containment), wn 1

primary containment is not required to be OPERABLE, or that take place outside primary containment.

The secondary containment is a structure that completely encloses the primary containment and those components that may be postulated to contain primary system fluid. This structure forms a control volume that serves to hold up and dilute the fission products.

It is possible for the pressure in the control volume to rise relative to the environmental pressure (e.g., due to pump / motor heat load additions). To prevent ground level exfiltration while allowing the secondary containment to be designed as a conventional structure, the secondary containment requires support systems to maintain the control volume pressure at less than the external pressure.

The isolation devices for the penetrations in the secondary containment boundary are a part of the secondary containment barrier. To maintain this barrier:

a.

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

1.

capable of being closed by an OPERABLE secondary containment automatic isolation system, or (continued)

GRAND GULF B 3.6-83 Revision No. O

Secondary Containment B 3.6.4.1 BASES BACKGROUND 2.

closed by a manual valve, blind flange, rupture (continued) disk, or de-activated automatic valve or damper secured in a closed position, except as provided in LC0 3.6.4.2, " Secondary Containment Isolation Valves (SCIVs)";

b.

All auxiliary building and enclosure building equipment hatches and blowout panels are closed and sealed; c.

The door in each access to the auxiliary building and enclosure building is closed, except for normal entry and exit; d.

The sealing mechanism, e.g., welds, bellows, or 0-rings, associated with each secondary containment penetration is OPERABLE; and e.

The standby gas treatment system is OPERABLE, except as provided in LCO 3.6.4.3, " Standby Las Treatment System."

APPLICABLE There are three principal accidents for which credit is SAFETY ANALYSES taken for secondary conta_i_nment OPERABILITY. These are a J LQ P

LOCA (Ref.1), a fuel handling accidenhinside primary f 6 35.-T/SJ containment (Ref. 2). and a fuel handling accidentsin the auxiliary builaTng (Ref. 3). The secondary containment r

' g__ gyg performs no active function in response to each of these limiting events; however, its leak tightness is required to ensure that the release of radioactive materials from the primary containment is restricted to those leakage paths and associated leakage rates assumed in the accident analysis, and that fission products entrapped within the secondary containment structure will be treated by the SGT System prior to discharge to the environment.

Secondary containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 An OPERABLE secondary containment provides a control volume into which fission product:: that bypass or leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, can be diluted and processed prior to release (continued)

GRAND GULF B 3.6-84 Revision No. O

f! 3 t

L-i Proposed inserts to Bases for TS 3.6.4.1 INSERT B 3.6-84A-involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days)

INSERT B 3.6-84B involving the handling of recently irradiated fuel INEERT B 3.6-85A Due to radioactive decay, secondary containment is required to be OPERABLE only during that fuel movement involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days).

i 4

i l

i Secondary Containment B 3.6.4.1 BASES LC0 to the environment.

For the secondary containment to be (continued) considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained.

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential g for drainiqg the reactor vessel (OPDRVs) f t " C a

~

wLTER;,T!0% or during movemendt o irradiated fuel

- g6g assemblies in the primary or/f u nndary containment.

reeuntM 87 G-f6 A N

ACTIONS A.1 If secondary containment is inoperable, it must be restofed to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the ' problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3.

This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

B.1 and B.2 If the secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

(continued)

GRAND GULF B 3.6-85 Revision No. O

Secondary Containment 3 3.6.4.1 BASES And ACTIONS C.1&C.

7 (continued)

V Movement of4irradiat d fuel assemblies in the primary or gg[/

secondary containment, m0ri A!"'ATIONQ and OPDRVs can be postulated to cause ission product release to the secondary containment.

In such cases, the secondary containment is 6 *9'"g the only barrier to release of fission products to the 2

5

._ environment.1!@oE RTERATIC;G sn@aovement o7 rradiated fi fuel assemblies must be immediately suspended 1f the CTT<c$^

secondary containment is inoperable.

(retcn.e h

Suspension of these activities shall not preclude comp.eting an action that involves moving a component to a safe.

position. Also, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until 0PD Ve m "moended.

reeercly)

Required Action C.1 has been modified by a Note stTting that LC0 3.0.3 is not applicable.

If moving irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3 would not specify any action.

If movin% irradiated fuel assemblies while in j

MODE 1, 2, or 3, the fuel movement is independent of reactor (YC

'[

operations. Therefore, in either case, inability tb suspend movement o irradiated fuel assemblies would not be a sufficien reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.1.1 and SR 3.6.4.1.2 REQUIREMENTS Verifying that Auxiliary Building and Enclosure Building equipment hatches, blowout panels, and access doors are closed ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur.

In this application the term " sealed" has no connotation of leak tightness. Maintaining secondary containment OPERABILITY requires verifying each door in the access opening is closed, except when the access opening is being used for entry and exit. The 31 day Frequency for these Srs has been shown to be adequate based on operating experience, and is considered adequate in view of the other controls on secondary containment access openings.

(continued)

GRAND GULF B 3.6-86 Revision No. O

4 SCIVs.

B 3.6.4.2 BASES BACKGROUND Analyses have shown that in addition to_ building leakage (continued) paths, the Standby Gas Treatment System (SGTS) has the capacity to maintain secondary containment negative pressure assuming the failure of-all nonqualified lines 2 inches and smaller or with the failure of-a single nonisolated line as large as 4 inches. As a result, the following lines which penetrate the secondary containment and terminate there (i.e., they do not continue.through the secondary containment and also penetrate the primary containment) are provided with.a single isolation valve, rather than two, at the secondary penetration:

a.

4-inch makeup water supply line b.

3-inch domestic water supply line c.

4-inch RHR backwash line d.

3-inch backwash transfer pump discharge line e.

3-inch floor and equipment drain line The single isolation valve for each of the above lines is an air-operated valve which fails closed; in addition, each operator is provided with redundant solenoid valves which receive actuation signals from redundant sources.

In this manner, it is ensured that, given any single failure, onTy/

one of the above lines will be nonisolated, which as stated above is within the capacity of the SGTS.

APPLICABLE The SCIVs must be OPERABLE to ensure the secondary I TC33.x t SAFETY ANALYSES containment barrier to fission product releases is 63 3.c 1 1 6 established. The principal accidents for which the

~

secondary containment boundary is required are a loss;of coolant accident (Ref.1), a fuel handling accidentnnside acc3 sge F l

primary containment (Ref. 3), and a fuel handling accident A

<3g;A,<pq;9 pin the auxiliary building (Ref. 4). The secondary containment performs no active function in response to each of these limiting events, but the boundary established by SCIVs is required to ensure that leakage from the primary containment is processed by the Standby Gas Treatment (SGT)

System before being released to the environment.

(continued)

GRAND GULF B 3.6-89 Revision No. O

Proposed inserts to Bases for TS 3.6.4.2 INSERT B 3.6-89A

~

involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days)

INSERT B 3.6-89B involving the handling of recently irradiated fuel INSERT B 3.6-90A Due to radioactive decay, the SCIVs are required to be OPERABLE only during that fuel movement involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a -

critical reactor core within the previous 8 days).

e L

SCIVs B 3.6.4.2 BASES

'A?PLICABLE Maintaining.SCIVs OPERABLE with isolation times within SAFETY ANALYSES limits ensures that fission products will remain trapped (continued) inside secondary containment so that they can be treated by the SGT-System prior to discharge to the environment.

SCIVs satisfy Criterion 3 of the NRC Policy Statement.

LC0 SCIVs' form a part of the secondary containment boundary. The SCIV safety function is.related to control of offsite radiation. releases resulting from DBAs.

The power operated isolation dampers and valves are considered OPERABLE when their isolation times are within limits. Additionally, power operated automatic dampers and valves are required to actuate on an automatic isolation signal.

The normally closed isolation dampers and valves, rupture disks, or blind flanges are considered OPERABLE when manual dampers and valves are closed or open in accordance with appropriate administrative controls, automatic dampers and valves are de-activated and secured in their closed position, rupture disks or blind flanges are in place. The SCIVs covered by this LCO, along with their associated stroke times, if applicable, are listed in the applicable plant procedures.

APPLICABILITY In MODES 1, 2, and 3, a DBA cculd lead to a fission product release to the primary containment that leaks to the secondary containment. Therefore, OPERABILITY of SCIVs is required.

In MODES 4 and 5, the probhility and consequences of these events are reduced due to pressure and temperature limitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations with a ootential for draining the reactor vessel (OPDRVs

" '--^ "

( CORE SLTE'".T:GNQ or during movement o irradiated assemblies. Mov7ng rradiated fuel assemblies in the primary or secondary containment may also occur in MODES 1,

'4 gg (continued) 836-90A GRAND GULF B 3.6-90 Revision No. O

SCIVs B 3.6.4.2 BASES ACTIONS C.1 and C.2 (continued) reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an or

" manner and without challenging plant systems.

n D.hD.2 D.b)

If any Required Action and associated Completion Time cannot be met, the plant must be placed i ga condition in which the LCO does not apply.

If applicable,w^"E."f^^"^5 9)the h3 movement ofmirradiated fuel assemblies in the primary and

( (CCcnllyJP secondary containment must be immediately suspended.

k Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

Required Action 0.1 has oeen modified by a Note stating that g g g \\f LC0 3.0.3 is not applicable.

If moving irradiated fuel Nany a_blies while TlFMODE 4 or 5, LC0. 3 would not specify f

assem ction.

If moving 4 irradiated fuel assemblies while in MODE 1, 2, or 3, the Tuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement o irradiated fuel assemblies would not be a sufficient eason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.2.1 REQUIREMENTS This SR verifies each secondary containment isolation manual valve, damper, rupture disk, and blind flange that is required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or SCIV manipulation. Rather, it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position.

Since these SCIVs are readily accessible to personnel during.

normal unit operation and verification of their position is (continued)

GRAND GULF B 3.6-93 Revision No. O

1.

SGT System B 3.6.4.3 BASES BACKGROUND' humidity.of the. airstream to.less than 70% (Ref. 2). The (continued) prefilter removes large particulate matter, while the HEPA filter is provided to remove fine particulate matter and protect the charcoal from fouling. The charcoal adsorber removes gaseous elemental iodine and organic iodides, and the final HEPA filter is provided to collect any carbon fines exhausted from the charcoal adsorber.

The SGT System automatically scarts and operates in response to actuation signals inoicative of conditions or an accident that could require operation of the system. Following initiation, both enclosure building recirculation fans and both charcoal filter train. fans start. SGT System flows are controlled by modulating inlet vanes installed on the charcoal filter train exhaust fans and two position volume control dampers installed in branch ducts to individual regions of the secondary containment.

APPLICAdLE The design basis'for the SGT System is to mitigate the SAFETY ANALYSES consequences of a loss of coolant accident and fuel handling accidents,(Ref. 2). For all events analyzed, the SGT System

- bd

~ is shown to be automatically initiated to reduce, via 6 3,(o-T78 filtration and adsorption, the radioactive material released to the environment.

The SGT System satisfies Criterion 3 of the NRC Policy Statement.

LCO Following a DBA,-a minimum of one SGT subsystem is required

.to maintain the secondary containment at a negative pressure with respect to the environment and to process gaseous releases. Meeting the LC0 requirements for two operable subsystems ensures operation of at least one SGT subsystem in the event of a single active failure.

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

(continued)

GRAND GULF-B 3.6-97 Revision No. O l

\\

r

.* to GNRO-Proposed inserts to Bases for TS 3.6.4.3 INSERT B 3.6_97A Due to radioactive decay, the SGT System is required to be OPERABLE to mitigate only those fuel handling accidents involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days).

INSERT B 3.6-98A Due to radioactive decay, the SGT System is required to be OPERABLE only during fuel movement involving the handling of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 8 days).

SGT System B 3.6.4.3 BASES APPLICABILITY In MODES 4 and 5, the probability and consequences of these (continued) events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System OPERABLE is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material caa be postulated, such as during operations with a cotential for draining the reactor vessel (0PDRVsJi"We 0RE ^1TC"!O_"S,) or during movement of r

i reedl irradiated fuel assemblies in the primary or secondary containment.g iInse<~t63.6-4%A)

ACTIONS M

i With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days.

In this Condition, the remaining OPERABLE SGT subsystem is adequate I

to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem l

could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a DBA occurring during this period.

/

B.1 and B.2 If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LC0 does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 allenging plant systems.

nd d C.h.h

& [ C.1, C.2.1, C.2.

9 Daring movement oflirradiated fuel assemblies in the primary or secondary containment 7tri.,g - -....._ _..S3 or during

~

^

OPDRVs, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem (continued)

GRAND GULF B 3.6-98 Revision No. O

l i

SGT System B 3.6.4.3 i

BASES ACTIONS C.1, C.2.1.NC.2.

o.M C. 2.2 (continued)

{

w should be immediately placed in operation. This Required Action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

An alternative to Required Action C.1 is to immediately i

A suspend activities that represent a potential for releasing s'y,h h radioactive material to the secondary containment, thus

{

"A placingthegnitinaConMtinn that minimizes risk.

If J

applicable,w0C ALT ZT!0": =3movementofirradiatedfuel 4

d assemblies must be immediately suspended. Strspension of rf/J.nYh these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. This action should be chosen if the OPDRVs could be impacted by a loss of offsite power. Action must continue until OPDRVs are suspended.

The Required Actions of Condition C have been modified by a Note stating that LC0 3.0.3 is not applicable.

If moving

]

irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0 3 f

p would not specify any action.

If moving irradiated fuel '

assemblies while in MODE 1, 2, or 3, the uel movement is independent of reactor operations. Therefore, in either (YC@k case, inability to suspend movement irradiated fuel assemblies would not be a sufficient eason to require a reactor shutdown.

D.1 If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactivity release control function. Therefore, LC0 3.

ust be entered immediately.

E.11.

g Jhe two SGT su ystems are inoperable, if applicable eLT:^"! OMS -ad] movement o irradiated fuel assemblies in the primary and secondary con inment must be immediately DCf-P (continued) v GRAND GULF B 3.6-99 Revision No. O

l %

SGT System B 3.6.4.3 l

BASES N

E.hf.

b(continued)

ACTIONS suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until 0PDRVs are suspended.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem for a 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly.

It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for a 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.6.4.3.2 This SR verifie.s that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program.(VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 3).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR requires verification that each SGT subsystem starts

{

upon receipt of an actual or simulated initiation signal.

(continued) '

GRAND GULF B 3.6-100 Revision No. 0 l

L

ML20196G713

Text

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