Text

Forwards Drafted Comprehensive Bases Section & Improved TS for ISFSI for NRC Review,Per 971204 Discussion & 980218 Meeting W/Nrc
	ML20217N412
Person / Time
Site:	North Anna
Issue date:	04/01/1998
From:	Ohanlon J; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Paperiello C; NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
	97-716, NUDOCS 9804090096
	Download: ML20217N412 (78)
	v • d • e

., .

Vincisir ELECTRIC AND POWER CONWANY RicnuoNo %na:N 4 2326:

April 1, 1998 Mr. Carl J. Paperiello, Director Serial No.97-716 Office of Nuclear Material Safety and Safeguards NL&P/TJS: R0 U. S. Nuclear Regulatory Commission Docket Nos. 72-16 Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA INDEPENDENT SPENT FUEL STORAGE INSTAI I ATION flSFSI)

DRAFT IMPROVED TECHNICAL SPECIFICATIONS As a result of discussions between the NRC and Virginia Electric and Power. Company (Virginia Power) on December 4,1997, an initiative was undertaken to draft North Anna ISFSI Technical Specifications reformatted to the improved Standard TS format. In support of this initiative, a working meeting was held on February 18,1998 at Virginia Power's innsbrook Technical Center. During this meeting Virginia Power presented a first draft to the NRC staff personnel in attendance. As a result of the comments received during this meeting, Virginia Power has redrafted the North Anna ISFSI improved Technical Specifications. Additions.lly, l Virginia Power has drafted a comprehensive Bases Section for the ISFSI improved Technical Specifications. The improved Technical Specifications and Bases are attached for your review.

If you have any questions, please contact us.

Very truly yours, j

mw James P. O'Hanlon i Senior Vice President - Nuclear T Attachment l

Commitments made by this letter:

1. None.

1 . \ . kl r1 . h 9804090096 980401 PDR ADOCK 0500o338 Y PDR

l cc: U.S. Nuclear Regulatory Commission

Attention: Document Control Desk Washington, D.C. 20555-0001 Mr.'R. A. Musser l NRC Senior Resident inspector Surry Power Station I

Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station Mr. J. W. Shea Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission, Mail Stop 14-H-22 Washington, D. C. 20555 1

I l i i

l l

1

.g.

I l

l i

PROPOSED TECHNICAL SPECIFICATIONS FOR NORTH ANNA INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) 1

l. j l

t i-I i

l l

i t

i

i i

l o 1

TABLE OF CONTENTS 1

l 1.0 USE AND APPLICATION .................... 1.1-1 1.1 Definitions ...................... 1.1-1 1.2 Logical Connectors . . . . . . . . . . . . . . . . . . . 1.2-1 1.3 Compl eti on Times . . . . . . . . . . . . . . . . . . . . 1.3-1

'.4

., Frequency ....................... 1.4-1 2.0 FUNCTIONAL AND OPERATING LIMITS .............. 2.0-1 2.1 Functional and Operating Limits ............ 2.0-1 2.2 Functional and Operating Limits Violations . . . . . . . 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY . . . . 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ........ 3.0-2 3.1 SSSC INTEGRITY . . . . . . . . . . . . . . . . . . . . . 3.1-1 3.1.1 SSSC Cavity Vacuum Drying Pressure . . . . . . . . . 3.1-1 3.1.2 SSSC Helium Backfill Pressure ........... 3.1-2 3.1.3 SSSC Helium Leak Rate ............... 3.1-3 3.1.4 SSSC Seal Integrity ................ 3.1-4 3.1.5 SSSC Maximum Lifting Height ............ 3.1-5 3.2 SSSC CRITICALITY CONTROL . . . . . . . . . . . . . . . . 3.2-1 l 3.2.1 Dissolved Boron Concentration ........... 3.2-1 l i 3.3 SSSC RADIATION PROTECTION ............... 3.3-1

3.3.1 SSSC Average Surface Dose Rates .......... 3.3-1 l 3.3.2 SSSC Surface Contamination . . . . . . . . . . . . . 3.3-3 l 3.3.3 ISFSI Perimeter Radiation ............. 3.3-4

4.0 DESIGN FEATURES ...................... 4.0-1 4.0-1 4.1 Site . . . . . . . . . . . . . . . . . . . . . . . . . .

4.1.1 Site Location ................... 4.0-1 4.2 Storage Features . . . . . . . . . . . . . . . . . . . . 4.0-1 l

4.2.1 Storage Cask . . . . . . . . . . . . . . . . . . . . 4.0-1 4.2.2 Storage Capacity . . . . . . . . . . . . . . . . . . 4.0-1 l 4.2.3 Storage Pad .................... 4.0-1 l

l 5.0 ADMINISTRATIVE CONTROLS .................. 5.0-1 5.1 Responsibility . . . . . . . . . . . . . . . . . . . . . 5.0-1 5.2 Organization . . . . . . . . . . . . . . . . . . . . . . 5.0-2 5.3 Facility Staff Qualifications ............. 5.0-3 5.4 Procedures . . . . . . . . . . . . . . . . . . . . . . . 5.0-4 5.5 Programs . . . . . . . . . . . . . . . . . . . . . . . . 5.0-5 North Anna ISFSI i Amendment No.

I L. Definiti@ns 1.1 I

1.0 USE AND APPLICATION 1.1 - Definitions

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

The defined terms of this section a pear in capitalized type and are applicable throughout these Technic 1 Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

INDEPENDENT SPENT FUEL The facility within the perimeter fence STORAGE INSTALLATION licensed for storage of spent fuel within SSSCs.

(ISFSI)

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an SSSC while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the SSSC and end when the SSSC is suspended from the transporter.

SEALED SURFACE STORAGE SSSCs are storage containers for spent fuel CASKS (SSSCs) approved for use at the ISFSI.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SSSC containing spent fuel is sitting on a storage pad within the ISFSI perimeter.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on an SSSC loaded with one or more fuel assemblies when it is being moved to and from the ISFSI. TRANSPORT OPERATIONS begin when the SSSC is first suspended from the transporter and end when the SSSC is at its destination and no i longer suspended from the transporter.

1 UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SSSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the SSSC is no longer suspended by the ,

! transporter and end when the last fuel assembly is removed from the SSSC. l North Anna ISFSI 1.1-1 Amendment No.

. Logical Connectors 1.2 ,

1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

)

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and _QR. The physical arrangement )

of these connectors constitutes logical conventions with specific meanings.

4 BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic l is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting number of the Required Action)(i.e.,

left justified The successive with levels of the logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

EXAMPLES The following examples illustrate the use of logical connectors.

l (continued)

North Anna ISFSI 1.2-1 Amendment No.

l l

l s

)

. Logical C nnectors 1.2 l

1.2 Logical-Connectors EXAMPLES EXAMPLE 1.2-1 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME i-A. LCO not met. A.1 Veri fy . . .

AND A.2 Restore . . .

In this example the logical connector AND is used to indicate that when in' Condition A, both Required Actions A.1 and A.2 must be completed.

i w

I l-(continued) t

i. North Anna ISFSI~ 1.2-2 Amendment No.

1 s

l

-)

. Logical Connectors 1.2 1.2 Logical Connectors i l

EXAMPLES EXAMPLE 1.2-2 l (continued)

ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME j A. LC0 not met. A.1 Stop . . . l E .

1 A.2.1 Verify . . . j i

AND !

A.2.2.1 Reduce . . . ;

i E l A.2.2.2 Perform . . .

E A.3 Remove . . .

I This example represents a more complicated use of logical j connectors. Required Actions A.1, A.2, and A.3 are !

alternative choices, only one of which must be performed as, indicated by the use of the logical connector E and the left justified placement. Any one of these three Actions may'be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be perfonned as indicated by the logical connector AND.

Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector M indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

i r

L North Anna ISFSI 1.2-3 Amendment No.

l .

Completion Times 1.3

-1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

L BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements' of the LC0 can fail to be met. S Required Action (s)pecified with each stated Condition are andCompletionTimes(s).

DESCRIPTION The Completion Time is the amourt of time allowed for

completing' a Required Action. It is referenced to the time l of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition

< unless otherwise specified, providing the facility is in a specified condition stated in the Applicability of the LCO.

Raquired Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition i remains in effect and the Required Actions apply until the i

Condition no longer exists or the facility is not within the l

LCO Applicability.

Once a Condition has been entered, subsequent subsystems, components, or variables expressed in the Condition, discovered to be not within limits, will not result.in; separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

(continued) i J'

f

' North Anna ISFSI 1,3-1 Amendment No.

l i ;

. Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.-

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and B.1 associated Completion AND Time not met. B.2 Perform Action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2 l

1 Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND complete action B.2 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for completirg action B.1 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for completing j action B.2 from the time that Condition B was entered. If '

action B.1 is completed within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

l

. 1 i

l i

(continued) 1 North Anna ISFSI 1.3-2 Amendment No.

r

..<. -);

t Complcticn Times

! 1 1.3 l

l 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

l A. One system. A.1 Restore system to- 7 days l:

not within within limit.

limit.

!- B. Required B.1 Complete action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months l Action and B.1 l associated l Completion AND

! Time not l

met. B.2 Complete action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i B.2 When a system is detennined to 'not meet the LCO, Condition A is entered. If the system is not restored within 7 days, i-Condition B is also entered and the Completica Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be tenninated.

I i-i i

(continued)

North Anna ISFSI 1.3-5 Amendment No. l

l - '

Completion Times -

1.3 1.3 Completion Times EXAMPLES . EXAMPLE 1.3-3 (continued)

ACTIONS

......__..............------N0TE--------------------------..

Separate Condition entry is allowed for each component.

l CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months compliance with LCO. ;

/

B. Required B.1 Complete action 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and B.1 associated Completion AND i

Time not met. . B.2 . Complete action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2 t

The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is trecked was applicable only to a specific Condition, the Note would appear in that

' Condition rath,er.than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for p' each component, and Completion Times tracked on a per l component basis. When a component is detemined to not meet j the LCO, Condition A is entered and its Completion Time L starts. If subsequent components are detemined to not meet the LCO, Condition A is entered for each com)onent and separate Completion Times start and are tracced for each component.

(continued)

North Anna ISFSI 1.3 4 Amendment No.

l

j s

I O

l. 1 !

Completicn Times 1.3 a

-l l '. 3 Completion Times (continued)

IMEDIATE - When "Innediately" is used as a Completion Time,-the COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.

3

-}l

)

i I

j l

North Anna ISFSI 1.3-5 Amendment No.

.(~

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR.

Situations where a Surveillance could be required (1.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such l that it is only " required" when it can be and should be l performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

- j l

l i

i l

I (continued)

North Anna ISFSI 1.4-1 Amendment No.

{- j L r 1

( 1.4 Frequency (continued)

EXAMPLES- The following examples' illustrate the various ways that j Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i Verify pressure within limit. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications The Frequency-specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months )(TS).

during which the associated

! Surveillance must be performed at least one time.

! Performance of the Surveillance initiates the subsequent L

interval. Although the Frequency is stated as 12~ hours, an extension of the time interval to 1.25 times the interval j specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to

! be met per SR 3.0.1 (such as when the equipment or a

! variable is outside specified limits, or the facility is l outside the Applicability of the LCO). If the interval l, specified by SR 3.0.2 is exceeded while the facility is in a l condition specified in the Applicability of the LCO, the LCO l- is not met in accordance with SR 3.0.1.

l If.the interval as specified by SR 3.0.2 is exceeded while the facility is not in a. condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be perfonned within the ,

l Frequency requirements of SR 3.0.2 prior to entry into the.

specified condition. Failure to do so would result in a j violation of SR 3.0.4.

i I

l (continued) ,

l 1

North Anna ISFSI l'.4-2 Amendment No.

- Frequency 1.4 I i

1.4 Frequency t

EXAMPLES EXAMPLE'1.4-2 (continued)

SURVEILLANCE REQUIREMENTS

)

SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting l

activity i AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months l l thereafter l

f Example 1.4-2 has two Frecuencies. The first is a one time '

)

performance Frequency, anc the second is of the type shown in Example 1.4-1.: The logical connector "AND" indicates l that both Frequent'y requirements must be met. Each time the l example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting the activity.

The use of "once" indicates a single performance will l

satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If the specified activity is canceled or not.

l performed, the measurement of both intervals stops. New

! intervals start upon preparing to restart the specified activity.

1 l

l 1

i i

? l North Anna ISFSI 1.4-3 Amendment No.

p I.

L j

I Functional and Operating Limits 2.0 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Functienal and Operating Limits 2.1.1 Fuel To Be Stored At The ISFSI The spent nuclear fuel to be stored in SSSCs at the North Anna ISFSI shall meet the following requirements:

a. Fuel assemblies shall be intact. Partial fuel assemblies, that is, fuel assemblies from which fuel rods are missing must not be loaded in SSSCs unless dummy fuel rods are used to displace an amount of water equal to that displaced by the original fuel rods.

b. Fuel assemblies known or suspected to have structural defects or gross cladding failures sufficiently severe to adversely affect fuel handling and-transfer capability shall not be loaded into SSSCs for storage,

c. Fuel assemblies shall meet the limits for initial enrichment, average burnup, cooling time after reactor discharge, decay heat, gamma and neutron source, and fuel assembly oesign as specified in Table 2.1-1.

2.2 Functional and Operating Limits Violations If any Functional and Operating Limits of 2.1.1 are violated, the following actions shall be completed:

2.2.1 The affected fuel assemblies shall be placed in r. safe condition.

2.2.2 Loading or transport of SSSCs shall not be resumed until authorized by the NRC.

l North Anna ISFSI 2.0-1 Amendment No, i

. Functional and Operating Limits 2.0 Table 2.1-1 (page 1 of 1)

Fuel Assembly Limits SSSC MODEL LIMIT

1. TN-32

a. Initial Enrichment 5 3.85 wt. %

b. Average Burnup 5 40,000 MWD /MTU

c. Cooling Time After Discharge 1 7 years

d. Decay Heat 5 0.847 kw/ assembly

e. Gamma Source per Cask 5 2.31E17 photons /second

f. Neutron Source per Cask 5 4.83E9 neutrons /second I I

g. Fuel Assembly Design Westinghouse 17x17 Standard Westinghouse 17x17 Vantage SH l l

1 1

i j

! North Anna ISFSI 2.0-2 knendment No.

I r i

l-

. LCO Applicability 3.0 1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1- LCOs shall. be met during specified conditions in the Applicability, except as'provided in LCO 3.0.2.

ll LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided.in LCO 3.0.5.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, unless otherwise stated.

LCO' 3.0.3 Not applicable to an ISFSI LCO 3.0.4 When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered pemit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes'in specified conditions in the Applicability that are required to comply with ACTIONS or that are related to the unloading of an SSSC.

f LCO 3.0.5 Equipment removed from service or not in service.in I compliance with. ACTIONS may be returned to service under i administrative control solely to' perform testing required to '

demonstrate it meets the LCO or that other. equipment meets the LCO. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform ,

the testing. l

+

6 LC0 3.0.6 Not applicable to an ISFSI '

\

LCO 3.0.7 Not applicable to an ISFSI North Anna ISFSI 3.0-1 Amendment No.

3

. SR Applicability !

3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY l

SR 3.0.1 SRs shall be met during the specified conditions in the l Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such ,

failure is experienced during the perfonnance of the I Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured froia the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the-initial performance. l Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed i within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from, the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow perfonnance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered.

(continued)

North Anna ISFSI 3.0-2 Amendment No.

r-l-

. SR Applicability

-3.0 I

3.0 SR APPLICABILITY (continued) l l

SR 3.0.4 Entry into a specified condition in the Applicability of an )

LC0 shall not be made unless the LCO's Surve111ances have

i. been met within their specified Frequency. This provision .

l. shall not prevent entry into specified conditions in the '

l Applicability that are required to comply with ACTIONS or l

that are related to the unloading of an SSSC.

l l

, i l

l l

\

North Anna ISFSI 3.0-3 Amendment No.

.- SSSC Cavity Vacuum Drying Pressure 3.1.1 l

( 3.1- SSSC INTEGRITY !

3.1.1' SSSC. Cavity Vacuum Drying Pressure .

i l LCO 3.1.1 The SSSC cavity vacuum drying pressure shall meet the limit specified in Table 3-1-for the applicable SSSC design.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

.....___..--------------------------.-NOTE-----..--------------...-..-....-.-.

Separate Condition entry is allowed for each SSSC.

l CONDITION . REQUIRED ACTION COMPLETION TIME I

A. SSSC cavity vacuum A.1 ' Establish SSSC cavity 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months drying pressure limit vacuum drying not met, pressure within i limit.

B. Required Action and B.1 Remove all fuel 7 days Associated Completion assemblies from the Time not met. SSSC.

i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l

SR 3.1.1.1 Verify SSSC cavity vacuum drying pressure Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is within limit. after removing SSSC from the spent fuel pool I

Morth Anna ISFSI , 3.1-1 Amendment No.

1

. - .~ u

.. SSSC Helium Backfill Pressure 3.1.2 3.'l - SSSC INTEGRITY 3.1.2 SSSC Helium Backfill Pressure LCO 3. I'.2 ' 'The SSSC helium backfill- pressure shall meet the limit specified in Table 3-1 for the applicable SSSC design.

' APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

.-------------NOTE------------------------------------

Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A.; SSSC helium backfill A.1 Establish SSSC helium 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months pressure limit not backfill pressure met. within-limit. i

)

i B. Required Action and B.I. Remove all fuel 7 days l Associated Completion assemblies from the !

Time not met. SSSC. ;

1

(

)

, SURVEILLANCE REQUIREMENTS SURVEILLANCE :

FREQUENCY i

SR 3.1.2.1 Verify SSSC helium backfill pressure is Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months within limit. after removing j SSSC from the i spent fuel pool North Anna ISFSI 3.1-2 Amendment No.

4

l'

- SSSC Helium Leak Rate 3.1.3 3.1 SSSC INTEGRITY l

l 3.1.3 SSSC Helium Leak Rate l

LCO 3.1.3 The SSSC helium leak rate for all closure seals.shall .not

! exceed the limit specified in Table 3-1 for the applicable l

SSSC design.

I APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC helium leak " ate A.1 Establish SSSC helium 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months limit not met. leak rate within limit.

1 B.- Required Action and B.1 Remove all fuel 7 dayt i Associated Completion assemblies from the j Time not met. SSSC. ;

I l

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify SSSC helium leak rate is within Within 5 days ,

limit, after removing I SSSC from the spent. fuel pool i

North Anna ISFSI 3.1-3 Amendment No.

. SSSC Seal Integrity I 3.1.4 3.1 SSSC INTEGRITY 3.1.4 SSSC Seal Integrity 1

LC0 3.1.4 The SSSC seal integrity shall be maintained.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC seal integrity A.1 Restore SSSC seal 30 days not maintained. integrity.

B. Required Action and B.1 Remove all fuel 7 days Associated Completion assemblies from the Time not met. SSSC.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify SSSC seal integrity in accordance 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with Table 3-1.

< North-Anna ISFSI 3.1-4 Amendment No.

~

i i

. SSSC Maximum Lifting Height' l 3.1.5 l

3.1 SSSC INTEGRITY l 3.1.5 SSSC Maximum Lifting Height l

LC0 3.1.5 The SSSC lifting height shall not exceed the limit in Table 3-1.

1 l

l APPLICABILITY: During TRANSPORT OPERATIONS.

i.

l ACTIONS

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

Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC lifting height A.1 Initiate action to Imediately l

higher than limit. restore SSSC lifting height within limit.

l l SURVEILLANCE REQUIREMENTS l

l SURVEILLANCE FREQUENCY

.SR 3.1.5.1 Verify 55SC lifting height within limit. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to initiation of TRANSPORT OPERATIONS North Anna ISFSI 3.1-5 Amendment No.

1

)

.. Dissolved Boron Concentiation 3.2.1 l

l 3.2 SSSC CRITICALITY CONTROL l

l 3.2.1 Dissolved Boron Concentration l LCO 3.2.1 .The dissolved boron concentration of the water in the spent l . fuel pool and of the water added to the cavity of an SSSC shall be within limits specified in Table 3-1. )

l

! l APPLICABILITY: During LOADING OPERATIONS, I l During UNLOADING OPERATIONS.

i ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME l A. Dissolved boron A.1 Suspend LOADING Imediately concentration limit OPERATIONS.

not met.

AND A.2 Remove all fuel 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months assemblies from SSSC.

l l

l '

l North Anna ISFSI 3.2-1 Amendmer.1 No.

. Dissolved Boron Cone.entration 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR. 3.2.1.1 Verify dissolved boro: concentration limit Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in spent fuel pool water is met, prior to comencing LOAD!NG OPEkATIONS AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter SR 3.2.1.2 Verify dissolved boron concentration limit Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in spent fuel pool water is met. prior to flooding SSSC during UNLOADING OPERATIONS AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter i

l i

l North Anna ISFSI 3.2-2 Amendment No. !

l

SSSC Average Surface Dose Rates 3.3.1 L 3.3 SSSC RADIATION PROTECTION l

3.3.1 SSSC Average Surface Dose Rates i

LCO 3.3.1 The average surface dose rates of each SSSC shall not l

exceed:

a. 129 mrem / hour (neutron + gamma) on the side; and

b. 55 mrem / hour (neutron + gamma) on the top.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC average surface A.1.1 Administratively 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months dose rate limits not verify correct fuel met. loading.

AND A.1.2 Perform analysis to Prior to verify compliance TRANSPORT with the ISFSI OPERATIONS offsite radiation '

protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

l OR A.2 Remove all fuel 7 days assemblies from the SSSC.

North Anna ISFSI 3.3-1 Amendment No.

..- SSSC Average Surface Dose Rates 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY' SR. 3.3.1.1 Verify average surface dose' rates of SSSC Prior to containing one or more fuel assemblies TRANSPORT within limits. OPERATIONS North Anna ISFSI 3.3-2 ~ Amendment No.

a

. SSSC Surface C ntamination 3.3.2 3.3- SSSC RADIATION PROTECTION 3.3.2 SSSC Surface Contamination LCO 3.3.2 Removable contamination on the SSSC exterior surfaces shall not exceed:

a. 1000 dpm/100 cm' from beta and gamma sources; and

b. 20 dpm/100 cm from alpha sources.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

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

+ Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. 55SC removable surface A.1 Initiate action to Immediately contamination limits restore SSSC not met. removable surface contamination to within limits.

SURVEILLANCE REQUIREMENTS {

l SURVEILLANCE FREQUENCY l SR 3.3.2.1 Verify that the removable contamination on Prior to ;

exterior surfaces of SSSC containing one or TRANSPORT j more fuel assemblies within limits. OPERATIONS North Anna ISFSI 3.3-3 Amendment No.

.. ISFSI P;rimeter Radiatien 3.3.3 3.3 SSSC RADIATION PROTECTION 3.3.3 ISFSI Perimeter Radiation LCO 3.3.3 The ISFSI's contribution to the radiation doses (neutron + gamma) at the ISFSI perimeter fence shall not exceed the limits provided in Figure 3.3.3-1.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ISFSI perimeter A.1 Initiate action to Immediately radiation not within restore ISFSI limits. perimeter radiation <

to within limits. j i

i l

l SURVEILLANCE REQUIREMENTS

]

SURVEILLANCE FREQUENCY

)

SR 3.3.I.1 Verify ISFSI's contribution to radiation 92 days doses (neutron + gamma) at ISFSI perimeter fence does not exceed the specified limits.

i North Anna ISFSI 3.3-4 Amendment No.

l

. ISFSI Perimeter Radiation 3.3.3 North' Fence PERIMETER FENCE N

N i'

( PAD a3 ( PAD

1 E PAO "2 O b

,,, ! O i w i :c t . so !

E O U E-Y East

! west $

y olo Fence Fence l j

E $$ -

t' I ool l

t Y T i:~

l 7ee- ise- 2ee- 2ee-South Fence West Fence Limit: 0.327 mrem / Hour North Fence Limit: 0.160 mrem / Hour East Fence Limit: 1.020 mrem / Hour South Fence Limit: 0.609 mrem / Hour Figure 3.3.3-1 (page 1 of 1)

ISFSI Perimeter Radiation Limits North Anna ISFSI 3.3-5 Amendment No.

- ' SSSC Model-Depend:nt Limits Table 3-1 fable 3-l' (page 1 of 1)

SSSC Model-Dependent Limits SSSC MODEL LIMITS 1.- TN-32

a. Cavity Vacuum Drying Pressure s '3 mbar held for 10 minutes

b. Helium Backfill Pressure 2230 mbar i 100 mbar

c. Helium Leak Rate 51.0 X 10-5 mbar-liter /sec

d. Seal Integrity Verification Inter-Seal Pressure 1 3100 mbar

e. Dissolved Boron Concentration 1 2000 ppm

'f. Maximum Lifting Height $ eighteen inches l

l I

l l

North Anna ISFSI 3.3-6 Amendment No.

i l

- Di; sign Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1' Site Location The North Anna ISFSI is located approximately 2000 feet southwest of the North Anna Power Station Units 1 and 2 protected area and within the boundaries of the North Anna site. The North Anna site is located in the north-central portion of Virginia in Louisa County and is approximately_40 miles north-northwest of Richmond, 36 miles east of Charlottesville; 22 miles southwest of Fredericksburg; and 70 miles southwest of Washington, D.C. The site is on a peninsula on the southern shore of Lake Anna at the end of State Route 700.

4.2 Storage Features 4.2.1 Storaae Cask The North Anna ISFSI is licensed to store spent fuel in the TN-32 dry storage cask.

4.2.2 Storaae Capacity The total storage capacity of the North Anna ISFSI is limited to 839.04 metric tons uranium.

4.2.3 Storace Pad The North Anna ISFSI storage pads are reinforced concrete, with nominal dimensions of 224 feet x 32 feet x 2 feet thick with a.40-foot ramp on each end for vehicle access. Each pad is designed to store 28 SSSCs arranged in two rows. The SSSCs in each row will be spaced a nominal 16 feet apart center to center. Each row of SSSCs will be spaced a nominal 16 feet apart center to center.

The facility will have up to three storage pads.

North Anna ISFSI 4.0-1 Amendment No.

l l

. RIsponsibility 5.1 5.0 ADMINISTRATIVE CONTROLS l

5.1 Responsibility l 5.'1.1 The plant manager shall be responsible for overall ISFSI operation and shall delegate in writing the succession to this responsibility during. his absence.

l The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to l systems or equipment that affects nuclear safety. l i

1 i

j l

1

! I l

l i

l l

I l

North Anna ISFSI 5.0-1 Amendment No.

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Oraanizations Onsite and offsite organizations shall be established for facility operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the ISFSI.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these. Technical Specifications, shall be documented in the Safety Analysis Report or the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report;

b. The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe operation and maintenance of the facility;

c. The responsible corporate executive shall have corporate responsibility for overall facility nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure nuclear safety; and

d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

North Anna ISFSI 5.0-2 Amendment No.

Facility Staff Qualifications 5.3 5.0 . ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications

5. 3 .1 - Each member of the' facility staff shall meet or exceed the minimum qualifications of ANS 3.1 (12/79 Draft) for comparable positions except that the Superintendent - Radiological Protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. Additional exceptions are specified in the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report.

l

)

North Anna ISFSI 5.0-3 Amendment No.

j

._- .Prccedur;s 5.4 5'. 0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 .Written procedures shall be established, implemented, and maintained covering the following activities:

a.- Administrative' controls;

b. Routine ISr;I operations;

c. Alarm and annunciator response;

d. Emergency operations;

e. Design _ control and facility change or modification;

f. Control of surveillances~and tests;

g. Control of special-processes;

h. Maintenance;

i. Health physics, including'ALARA practices;

j. Special nuclear' material accountability;

k. Quality assurance, inspection, and audits;

< '1. Physical security and safeguards; m.. Records management; and

n. All programs specified in Specification 5.5.

The above procedures may be common with the North Anna Power Station procedures provided that all ISFSI requirements. are_ met.

/

North Anna ISFSI 5.0-4 Amendment No.

Programs 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs The following programs shall be established, implemented, and maintained.

5.5.1 Technical Specifications (TS) Bases Control Proaram This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS.shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the SAR or Bases that involves an unreviewed safety question, a significant increase in occupational exposure, or a significant unreviewed environmental impact as defined in 10 CFR 72.48.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the SAR.

d. Proposed changes that meet the criteria of 5.5.1.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without ;

prior NRC approval shall be provided to the NRC on a i frequency consistent with 10 CFR 72.48(b)(2).

l i

i 1

i North Anna ISFSI 5.0-5 Amendment No. 4

i 1

l l

i l

l l

PROPOSED TECHNICAL SPECIFICATIONS BASES FOR NORTH ANNA INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) ;

i 1

l l

1 i

)

1

~

j

TABLE Of CONTENTS 2.0 FUNCTIONAL AND OPERATING LIMITS ............. B 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY . . . B 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ....... B 3.0-5 3.1 SSSC INTEGRITY . . . . . . . . . . . . . . . . . . . . B 3.1-1 3.1.1 SSSC Cavity Vacuum Drying Pressure . . . . . . . . B 3.1-1 3.1.2 SSSC Helium Backfill Pressure .......... B 3.1-4 3.1.3 SSSC Helium. Leak Rate .............. B 3.1-7 3.1.4 SSSC Seal Integrity ............... B 3.1-10 3.1.5 SSSC Maximum Lifting Height ........... B 3.1-13 3.2 SSSC CRITICALITY CONTROL . . . . . . . . . . . . . . . B 3.2-1 3.2.1 Dissolved Boron Concentration .......... B 3.2-1 3.3 SSSC RADIATION PROTECTION .............. B 3.3-1 3.3.1 SSSC Average Surface Dose Rates ......... B 3.3-1 3.3.2 SSSC Surface Contamination . . . . . . . . . . . . B 3.3-4 3.3.3 ISFSI Perimeter Radiation ............ B 3.3-7 1

l i

North Anna ISFSI i Amendment No.

Functional: and Operating Limits B 2.0 B 2.0 FUNCTIONAL'AND OPERATING LIMITS

. B 2.1.1 Fuel to be Stored at the ISFSI BASES BACKGROUND- 10 CFR 72.236(a) requires that specifications must be provided for the spent fuel to be stored in.each type of SSSC such as type of spent-fuel, maximum allowable enrichment prior to irradiation, umximum burnup, minimum acceptable cooling time prior to storage in the SSSC, maximum decay heat, and conditions of the spent fuel (i.e.,

intact' assembly or consolidated fuel rods). Other important limitations are the radiological source terms for the fuel assemblies.

These limitations are assumptions in the thermal, structural, radiological, and criticality evaluations performed for each SSSC_ design and are specified in Table

, -2.1-1 for each SSSC design approved for use at the ISFSI.

. APPLICABLE An analysis of the storage of an unauthorized fuel assembly SAFETY ANALYSIS is presented in SAR Section 8.2.6-(Ref. 1). The analysis 4 demonstrates that placement of an unauthorized fuel assembly '

in an SSSC has no adverse effects while the SSSC is located j in the spent fuel pool. . To ensure that the 110 is not 1 placed on an SSSC containing an unauthorized fuel assembly, l facility procedures require verification of the loaded fuel l assemblies to ensure that the correct fuel assemblies have been loaded in the SSSC.

l

)

North Anna ISFSI B 2.0-1 Amendment No.

r a Functicnal and Operating Limits B 2.0 i

BASES (continued)

FUNCTIONAL AND The following Functional and Operating Limits violation OPERATING LIMITS responses are applicable.

VIOLATIONS 2.2.1 If Functional and Operating Limit 2.1.1 is violated, the limitations on the fuel assemblies in the SSSC have not been met.- Actions must be taken to place the affected fuel assemblies in a safe condition. This safe condition may be established by returning the affected fuel assemblies to the spent fuel' pool. However, it is acceptable for the affected fuel assemblies to remain in the SSSC if that is determined to be a safe condition.

2.2.2 Reporting of the violation of a Functional and Operating Limit to the NRC is required by 10 CFR 72.75. Loading or transport.of SSSCs may not be perfonned until after authorization is received from the NRC. This' requirement ensures the NRC that all necessary reviews, analyses, and l actions are completed before the restart of normal operation.

REFERENCES 1. SAR, Section 8.2.6.

1 I

4 I

North Anna ISFSI- B 2.0-2 Amendment No.

l

LC0 Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1, 3.0.2, 3.0.4 and 3.0.5 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within i each individual Specification as the requirement for when l the LCO is required to be met (i.e., when the unit is in the specified conditions of the Applicability statement of each ,

Specification). ]

I

)

LC0 3.0.2 LC0 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS I Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required l when an LC0 is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LC0 must be met. This time limit is the Completion Time to ,

restore a system or component or to restore variables to i within specified limits. Whether stated as a Required ;

Action or not, correction of the entered Condition is an '

action that may always be considered upon entering ACTIONS.

The second type of Required Action specifies the remedial !

measures that pennit continued operation that is not further ,

restricted by the Completion Time. In this case, compliance (continued)

North Anna ISFSI B 3.0-1 Amendment No.

, . LCO Applicability l B 3.0 I

i BASES l

LC0 3.0.2 with the Required Actions provides an acceptt.ble level of l (continued) safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

i The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done ,

in a manner that does not compromise safety. Intentional j entry into ACTIONS should not be made for operational convenience.

! LCO 3.0.3 This specification is not applicable to an ISFSI. The placeholder is retained for consistency with the power reactor technical specifications.

LCO .3.0.4 LCO 3.0.4 establishes limitations on changes in specified conditions in the Applicability when an LCO is not met. It precludes placing the unit in a specified condition stated in that Applicability (e.g., Applicability desired to be antered) when the following exist:

a. Facility conditions are such that the requirements of l the LCO would not be met in the Applicability desired i to be entered; and

b. Continued noncompliance with the LCO requirements, if ..

the Applicability were entered, would result in the j facility being required to exit the Applicability desired to be entered to comply with the Required Actions. j (continued)

North Anna ISFSI B 3.0-2 Amendment No, i

L l

.. e LCO Applicability B 3.0 BASES: (continued) .

LCO'3.0.4 : Compliance with Required Actions that pemit continued (continued) operation of the facility for an unlimited period of time in a specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the facility. Therefore, in such cases, entry into a specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

The provisions of this Specification should not.be interpreted as endorsing the failure to exercise the good practice of restoring systems or components before entering an associated specified condition in the Applicability.

The provisions of LCO.3.0.4 shall not prevent changes.in specified. conditions in the Applicability that are_ required to comply with ACTIONS. In addition, the provisions of-LC0 3.0.4 shall not prevent changes in-specified conditions in the Applicability that are related to the unloading'of. an SSSC.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. Exceptions may apply to all the ACTIONS or

, to a specific Required Action of a Specification.

.LC0 .3.0.5 LCO 3.0.5 establishes'the allowance for restoring equipment to service.under administrative controls when it has been removed from service or detemined to not meet the LCO to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action (s)) to allow the performance of SRs to demonstrate:

a. The equipment being returned to service meets the LC0; or

b. Other equipment meets' the applicable LCOs.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the

. ACTIONS is limited to the time absolutely necessary to perform the allowed testing. This Specification does not (continued)

North Anna.ISFSI B 3.0-3 Amendment No.

i

. LCO Applicability B 3.0 l BASES'(continued) l LCO 3.0.5 . provide time to perfonn any other preventive or corrective l (continued) maintenance. !

l LCO 3.0.6 This specification is not applicable to an ISFSI. The placeholder is retained for consistency with the power reactor technical specifications.

1 I

LC0 3.0.7 This specification is not applicable' to an ISFSI. The I placeholder is retained for consistency with the power reactor technical specifications.

i l

l I

l l

f I l

.?

North Anna ISFSI B 3.0-4 Amendment No.

1

r

.- SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES-l SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply ~at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must-be met l during the specified conditions in the Applicability for l which the requirements of the LCO apply, unless otherwise L specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the. .

systems, components, and that variables are within specified !

l limits. Failure to meet a Surveillance within the specified !

( Frequency, in accordance with SR 3.0.2, constitutes a !

L failure to meet an LCO. I l Systems and components are assumed to meet the LCO when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that i systems or components meet the associated LCO when: !

a. The systems or components are known to not meet the LCO, although still meeting the SRs; or

b. The requirements of the Surveillance (s) are known not l to be met between required Surveillance performances. )

Surveillances do not have to be performed when the facility l l 1s in a specified condition for which the requirements of

the associated LCO are not applicable, unless otherwise specified.

Surve111ances, including Surve111ances invoked by Required l' Actions, do not have to be performed on equipment that has been determined to not meet the LCO because the ACTIONS define the remedial measures that apply. Surveillances have to be met and perfonned in accordance with SR 3.0.2, prior to returning equipment to service. Upon completion.of' maintenance, appropriate post maintenance testing is L

required. This includes ensuring applicable Surveillances are not failed and their most recent performance is in L

accordance with SR 3.0.2. Post maintenance testing may not ;

be possible in the current specified conditions in the i (continued) j i

North Anna ISFSI B 3.0-5 Amendment No.

l

SR Applicab!11ty B 3.0 BASES

'SR 3.0.1 Applicability due to the necessary facility parameters.not-(continued) having been established.. In these situations, the equi xnent may be considered to meet the LCO provided testing has >een. <

satisfactorily completed to the extent. possible and the

~

equipment is not otherwise believed to be incapable of-performing its function. This will allow operation to proceed to a specified condition where other necessary post maintenance tests can be completed.

)

~

.SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surve111ances and any Required i Action with a Completion Time that requires the periodic perfonnance of the Required Action on a "once per . . ."

interval.

SR 3.0.2 pennits a 25% extension of the interval specified in the, Frequency. _This extension ~ facilitates Surveillance.

scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g.,

transient conditions or other ongoing Surveillance or- 1 maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at '

its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being perfonned is the verification of conformance with the SRs. The exceptions to SR.3.0.2 are those.Surveillances for which the 25% extension of the interval specified in the .

Frequency does not apply. These exceptions are stated in

-the individual. Specifications as a Note in the Frequency stating, "SR 3.0.2 is not applicable."

As stated.in SR 3.0.2, the 25%_ extension.also does not apply to the initial portion of 'a periodic Completion Time that requires performance on a "once per ..." basis. The 25%

extension' applies to each performance after the initial performance, tThe initial' perfonnance of the Required Action..whether it is a particular. Surveillance or some other remedial action,.is considered a single action with a single Completion Time. One reason for.not allowing the 25%

extension _ to this. Completion Time is that such an action

, i usually' verifies that no loss of function has occurred by

/ 7 checking the status of redundant or diverse components or (continued) i North Anna ISFSI B 3.0-6 Amendment No.

u-

I i

.. SR Applicability l B 3.0 l

BASES SR 3.0.2 accomplishes the function of the affected equipment in an

.(continued) alternative manner.

l The provisions of SR 3.0.2 are not intended to be used

! repeatedly merely as an operational convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment as not meeting the LCO or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specifiec Frequercy was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period '

permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of facility conditions, adequate planning, availability of ,

personnel, the time required to perfonn the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of confonnance with the requirements. When a Surveillance with a Frequency based not on time intervals, but upon specified facility conditions or operational situations, is discovered not to have been performed when specified, SR 3.0.3 allows the full delay period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the Surveillance.

SR 3.0.3 also provides a time limit for completion of Surveillances that become applicable as a consequence of ,

changes in the specified conditions in the Applicability ;

imposed by Required Actions. l f 1 i

Failure to comply with specified Frequencies for SRs is l expected to be an infrequent occurrence. Use of the delay I

(continued)

North Anna ISFSI B 3.0-7 Amendment No. 1 l

i

. SR Applicability B 3.0 l i

BASES SR 3.0.3 period established by SR 3.0.3 is a flexibility which is not i (continued) intended to be used as an operational convenience to extend i

Surveillance intervals.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered to not meet the LC0 l or the variable is considered outside the specified limits '

and the Completion Times of the Required Actions for the i applicable LCC Conditions begin immediately upon expiration l of the delay period. If a Surveillance is failed within the i delay period, then the equipment does not meet the LCO, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable-LC0 Conditions begin insnediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. i I

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs j must be met before entry into a specified condition in the <

App'licchility.

l This Specification ensures that-system and component i requirements and variable limits are met before entry in to l specified conditions in the Applicability for which these !

sys:ess and components ensure safe operation of the ;

facGity.

The provisions of this Specification should 'not be I interpreted as endorsing the failure to exercise the good i practice of restoring systems or components before entering .

an associated specified condition in the Applicability, i However, in certain circumstances, failing to meet an ER will not result in SR 3.0.4 restricting a change in specified condition. When a system, subsystem, component, device, or variable is outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be

! performed on such equipment. When equipment does not meet l the LCO, SR 3.0.4 does not apply to the associated SR(s) l (continued)

North Anna ISFSI B 3.0-8 Amendment No.

. SR Applicability B 3.0 BASES I

SR 3.0.4 since the requirement for the SR(s) to be performed is j (continued) removed. Therefore, falling to perfonn the Surveillance (s) within the specifief Frequency does not result in an SR 3.0.4 restriction to changing specified conditions of the Applicability. However, since the LCO is not met in this instance, LC0 3.0.4 will govern any restrictions that may (or may not) apply to specified condition changes.

The provisions of SR 3.0.4 shall not prevent changes in j specified conditions in the Applicability that are required -

to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are related to the unloading of an SSSC.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allews performance of Surveillances when the prerequisite condition (s) specified in a Surveillance procedure require entry into the specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be perfonned until after entering the LC0 Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met.

4 l

North Anna ISFSI B 3.0-9 Amendment No.

i

. SSSC Cavity Vacuum Drying Pressure B 3.1.1 B 3.1 SSSC INTEGRITY B 3.1.1 SSSC Cavity Vacuum Drying Pressure BASES i

)

BACKGROUND An SSSC is placed in the spent fuel pool and loaded with fuel assemblies meeting the requirements of the Functional and Operating Limits. A lid is then placed on the SSSC.

The SSSC is raised to the spent fuel pool surface and water is pumped from the SSSC fuel cavity. -The SSSC is then moved into a cask bay and the lid is secured. Vacuum drying of I

the SSSC cavity is perfonned. The cavity is backfilled with helium and the SSSC seals are tested. The SSSC surfaces are j decontaminated. Any additional lids are attached and any I instrumentation used to monitor the SSSC for seal leakage is installed. Surface radiation dose measurements are completed prior to moving the SSSC to the ISFSI storage pad.

Cavity vacuum drying is utilized to remove residual moisture from the SSSC fuel cavity after the SSSC has been drained of water. Any water which was not drained from the fuel cavity evaporates from fuel or basket surfaces due to the vacuum.

This is aided by the temperature increase due to the heat generation of the fuel.

APPLICABLE The confinement of radioactivity during the storage of spent SAFETY ANALYSIS fuel in a SSSC is ensured by the use of multiple confinement barriers and systems. The barriers relied upon are the uranium dioxide fuel pellet matrix, the metallic fuel cladding tubes in which the fuel pellets are contained, and the SSSC in which the fuel assemblies are stored. Long-term integrity of the fuel cladding depends on storage in an inert atmosphere. This is accomplished by removing water i from the SSSC fuel cavity and backfilling the cavity with an

' inert gas. The failure of all confinement barriers is considered in the accident analysis (Ref. 1). In addition, the thennal analyses of the SSSC assume that the SSSC cavity is filled with dry helium.

(continued)

North Anna ISFSI B 3.1-1 Amendment No. t

)

I

<.- SSSC Cavity Vacuum Drying Pressure B 3.1.1 l

BASES (continued)

L

'^

LCO A stable vacuum pressure of less than that specified in-Table 3-1 indicates that all liquid water has evaporated-and been removed from the SSSC cavity. Removing water from the i SSSC fuel cavity helps to ensure the long-term maintenance i of fuel clad integrity.

u PB L APPLICABILITY- Cavity vacuum drying is perfonned during LOADING OPERATIONS before the SSSC is transported to the ISFSI storage pad.

Therefore,.the vacuum requirements do not apply after the

. - SSSC is backfilled with helium prior to TRANSPORT OPERATIONS and STORAGE OPERATIONS. I l

ACTIONS - A Note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SSSC.

.- This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SSSC not meeting the LCO. Subsequent SSSCs that don't meet the LCO are governed by subsequent Condition entry and application of associated Required Actions. l

-A.1 If the cavity vacuum drying pressure limit cannot be met, ,

actions must be taken to meet the LCO. Failure to

successfully complete cavity vacuum drying could have many causes, such as failure of the vacuum drying system, inadequate draining, ice clogging.of the drain lines, or leaking SSSC cavity seals. The provided Completion Time is sufficient to detennine and correct most failure mechanisms.

A.2

. If the SSSC fuel cavity cannot be successfully vacuum dried, ;

the fuel must be placed in a safe and analyzed condition in j the spent fuel pool. The Completion Time is reasonable i based on the time required to move and unload an SSSC in an orderly manner and without challenging the operating i personnel. i i

(continued) e North Anna ISFSI B 3.I-2 Amendment No.

I

, SSSC Cavity Vacuum Drying Pressure B 3.1.1 j i

BASES..(continued).

SURVEILLANCE SR 3.1.1.1 REQUIREMENTS The long-term integrity of the stored fuel is dependent on storage in a dry, inert environment. Cavity dryness is demonstrated by evacuating the cavity to a very low pressure F

and verifying that the pressure is held over a specified period of time. A constant vacuum pressure is an indication th't the cavity is dry.

This dryness test must he performed successfully on each SSSC. The test must be performed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of removing the SSSC from the spent fuel pool. This allows 3 sufficient time to prep'are the SSSC and perform the test while minimizing the time the fuel is in the SSSC without an inert atmosphere.

REFERENCES 1. SAR, Section 8.2.10.

l l

l I

i I

j l

i i

i North Anna ISFSI B 3.1-3 Amendment No.

1

'~~

.: SSSC' Helium Backfill Pressure

>- B 3.1.2

'B-3.1 SSSC INTEGRITY.

B 3.1.2 : SSSC Helium Backfill Pressure BASES.

BACKGROUND' : An SSSC is placed in 'the spent fuel-~ pool and loaded with -

fuel assemblies meeting the requirements of the Functional and Operating Limits. A lid is then placed on the SSSC.

'The SSSC is raised to the spent fuel pool surface and water is pumped from the SSSC fuel cavity. The SS?C is then moved into a cask bay and the lid is secured. Vacut- Jrying of the SSSC cavity is performed. The cavity is backfilled with helium and the SSSC seals are tested. The SSSC surfaces are decontaminated.. Any additional lids are attached and any

' instrumentation used to monitor the SSSC cavity pressure is installed. . Surface radiation dose measurements are completed prior to moving the SSSC to the ISFSI storage pad.

Backfilling the SSSC fuel cavity with helium promotes heat' transfer from the fuel and the inert atmosphere protects the fuel cladding. Providing a helium pressure greater than atmospheric pressure ensures that there will be no in-leakage of air over the life of the SSSC, which might"be

- hamful to the fuel.

7 APPLICABLE The confinement of radioactivity during the storage'of spent SAFETY ANALYSIS _ fuel in a SSSC is ensured by the use of multiple confinement barriers and systems. The barriers relied upon are the-

'" uranium dioxide fuel pellet matrix, the metallic fuel cladding tubes in which the fuel pellets are contained, and the SSSC in which the~ fuel assemblies are stored. Long-tem integrity of the fuel cladding depends on storage in an inert atmosphere. This is accomplished by removing water from the SSSC fuel cavity and backfilling the cavity with helium, an inert gas. This confinement of radioactive material is assumed in the loss of confinement barrier accidentanalysis.(Ref._1). In addition, the thermal analysis performed for the SSSCs in the Topical Safety Analysis Report cssumes the use of helium as a cover gas.

(continued) l North Anna ISFSI- B 3.1-4 Amendment No.

. SSSC Helium Backfill Pressure B 3.1.2 BASES (continued)

LCO Backfilling the SSSC_ fuel cavity with helium at a pressure exceeding atmospheric pressure will ensure'that there will be no air in-leakage into the cavity which could damage the fuel cladding. The helium pressure value specified in Table 3-1 was taken from the SSSC Topical Safety Analysis Report and was selected to ensure that the pressure within the SSSC remains within the design pressure limits over the life of the SSSC.

APPLICABILITY Helium backfill is performed during LOADING OPERATIONS prior I to transporting the SSSC to the ISFSI storage pad. The helium leak rate is then measured prior to TRANSPORT OPERATIONS and STORAGE OPERATIONS.

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SSSC. !

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SSSC not. meeting the LCO. Subsequent SSSCs that don't meet ~ i the LC0 are governed by subsequent Condition entry and application of associated Required Actions.

A.1 If the helium backfill pressure cannot be obtained, actions must be taken to meet the LCO. The provideJ Completion Time is sufficient to determine and correct most failures which would prevent backfilling of the SSSC fuel cavity with helium.

A.2 l 1

If the SSSC fuel cavity cannot be backfilled with helium to the specified pressure, the fuel. must be placed in a safe and analyzed condition in the spent fuel pool. The Completion Time is reasonable based on the time required to i move and unload an SSSC in an orderly manner and without challenging the operating personnel.

1 (continued)

North Anna ISFSI B 3.1-5 Amendment No.

~

SSSC Helium Backfill Pressure B 3.1.2 BASES (continued)

SURVEILLANCE SR 3.1.2.1 REQUIREMENTS The long-term integrity of the stored fuel is dependent on storage in an inert environment. Filling the SSSC fuel cavity with helium at the pressure specified in Table 3-1 will ensure that there will be no air in-leakage, which could potentially damage the fuel, and that the SSSC fuel cavity internal pressure will remain within limits for the life of the SSSC.

Backfilling with helium must be performed successfully on each SSSC. . The Surveillance must be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of removing the SSSC from the spent fuel pool. This allows sufficient time to prepare the SSSC, com)1ete vacuum drying, and backfill the SSSC fuel cavity with 1elium while minimizing the time the fuel is in the SSSC without the assumed inert atmosphere.

REFERENCES 1. SAR, Section 8.2.10.

1 North Anna ISFSI B 3.1-6 Amendment No. )

I

SSSC Helium Leak Rate B 3.1.3 B 3.1 SSSC INTEGRITY B 3.1.3 SSSC Helium Leak Rate BASES BACKGROUND An SSSC is placed in the spent fuel pool and loaded with fuel assemblies meeting the requirements of the Functional and Operating Limits. A lid is then placed on the SSSC.

The SSSC is raised to the spent fuel pool surface and water is pumped from the SSSC fuel cavity. The SSSC is then moved into a cask bay and the lid is secured. Vacuum drying of the SSSC cavity is performed. The cavity is backfilled with helium and the SSSC seals are tested. The SSSC surfaces are decontaminated. Any additional lids are attached and any instrumentation used to monitor the SSSC cavity pressure is installed. Surface radiation dose measurements are completed prior to moving the SSSC to the ISFSI storage pad.

Backfilling the SSSC fuel cavity with helium promotes heat transfer from the fuel and the inert atmosphere protects the fuel cladding. Prior to moving the SSSC to the storage pad, the helium leak rate is determined to ensure that the fuel is confined.

APPLICABLE The confinement of radioactivity during the storage of spent SAFETY ANALYSIS fuel in a SSSC is ensured by the use of multiple confinement barriers and systems. The barriers relied upon are the uranium dioxide fuel pellet matrix, the metallic fuel cladding tubes in which the fuel pellets are contained, and the SSSC in which the fuel assemblies are stored. This confinement of radioactive material is assumed in the analysis of accidents except for the loss of confinement barrier accident analysis (Ref.1).

(continued)

North Anna ISFSI B 3.1-7 Amendment No.

. SSSC Helium Leak Rate B 3.1.3 .

l l

BASES (continued) )

i i

LC0 Verifying that the SSSC fuel cavity is sealed by measuring ;

the helium leak rate will ensure that the assumptions in the accident analyses and radiological evaluations are maintained. The helium leak rate value specified in Table 3-1 was taken from the SSSC Topical Safety Analysis Report.

APPLICABILITY The helium leak rate measurement is performed during LOADING l OPERATIONS before the SSSC is transported to the ISFSI storage pad. Seal integrity is monitored during STORAGE OPERATIONS by LCO 3.1.4, Seal Integrity.

l ACTIONS A Note has been added to the ACTIONS which states that, for i this LCO, separate Condition entry is allowed for each SSSC.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each i SSSC not meeting the LCO. Subsequent SSSCs that don't meet '

the LCO are governed by subsequent Condition entry and application of associated Required Actions.

i A.1 l If the helium leak rate limit is not met, actions must be taken to meet the LCO. The provided Completion Time is I sufficient to determine and correct most failures which 4 would cause a helium leak rate in excess of the limit. i A.2 If the SSSC helium leak rate cannot be brought within the limit, the fuel must be placed in a safe and analyzed condition in the spent fuel pool. The Completion Time is reasonable based on the time required to move and unload an SSSC in an orderly manner and without challenging the operating personnel.

(continued)

North Anna ISFSI B 3.1-8 Amendment No.

a SSSC Helium Leak Rate B 3.1.3 I

BASES'.(continued) i SURVEILLANCE SR 3.1.3.1 REQUIREMENTS A primary design consideration of the SSSC is that it is essentially leak tight. Measuring the helium leak rate with .

l_ a helium leak detector demonstrates that the SSSC l confinement barrier is sealed.

Measuring the helium leak rate must be performed successfully on each SSSC. The Surveillance must be performed within 5 days of removing the SSSC from the spent.

l fuel pool. This allows sufficient time to prepare the SSSC, l complete vacuum drying, backfill the SSSC fuel cavity with helium, and perform the Surveillance while minimizing the time the fuel is in the SSSC without verifying that the SSSC is sealed.

REFERENCES 1. _SAR, Section 8.2.10.

l l

l 1

North Anna ISFSI B 3.1-9 Amendment No.

l_

l

. SSSC Seal Integrity B 3.1.4 l I

B 3.1 SSSC INTEGRITY l B 3.1.4 SSSC Seal Integrity BASES l

I BACKGROUND An SSSC is loaded, dried,'and sealed prior to being j transported to the ISFSI and placed on a storage pad. The :

SSSC is designed with redundant seals to contain the I radioactive material. In addition,10 CFR 72.122(h)(4) and 1 10 CFR 72.128(a)(1) state that the SSSCs must have the capability to be continuously monitored such that the licensee will be able to determine when corrective action ,

needs to be taken to maintain safe storage conditions. The i monitoring systems vary with SSSC design, but have several i factors in common: !

a. The ability to monitor a pressure that will indicate if SSSC seal integrity is compromised, such as inter-

. seal pressure or fuel cavity pressure; and

b. Local and remote alarms to notify the licensee that potential seal degradation has occurred.

Regardless of the method of monitoring used, it is necessary i to verify SSSC seal integrity at a regular interval. i l

l 1

APPLICABLE. The confinement of radioactivity during the storage of spent :

SAFETY ANALYSIS fuel in a SSSC is ensured by the use of multiple confinement barriers and systems. The barriers relied upon are the ;

uranium dioxide fuel pellet matrix, the metallic fuel cladding tubes in which the fuel pellets are contained, and the SSSC in which the fuel assemblies are stored. The failure of all confinement barriers is considered in the accident analysis (Ref.1). In addition, the thermal analyses of the SSSC assume that the SSSC cavity is filled ;

with dry helium.

l (continued)

North Anna ISFSI B 3.1-10 Amendment No.

!. SSSC Seal Integrity B 3.1.4 BASES -(continued)

LCO Verifying SSSC seal integrity ensures that the assumptions in the accident analyses and radiological evaluations are maintained. The method of verifying seal integrity varies with SSSC design and is specified in Table 3-1 for each design.

APPLICABILITY SSSC seal integrity verification is performed regularly during STORAGE OPERATIONS to confirm that the SSSC confinement barriers have not been compromised. During LOADING OPERATIONS, the seal integrity is verified prior to moving the SSSC to the ISFSI storage pads. Verification during TRANSPORT GPERATIONS is not possible as the SSSC is being moved. However, TRANSPORT OPERATIONS are brief and follow the verification performed during LOADING OPERAT:0NS and, therefore, does not represent a significant lapse in seal integrity monitoring.

, ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SSSC.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SSSC not meeting the LCO. Subsequent SSSCs that don't meet the LC0 are governed by subsequent Condition entry and application of associated Required Actions.

A.1 If the SSSC seal integrity is not maintained, actions must l be taken to meet the LCO. The provided Completion Time considers the time required to diagnose and repair seal integrity problems, including the potential action of moving '

the SSSC into the power station protected area for repairs.

l (continued) l North Anna ISFSI B 3.1-11 Amendment No.

j

~

o. SSSC Seal Integrity B 3.1.4 BASES ACTIONS A.2 (continued)

If SSSC seal integrity cannot be established within the ,

Completion Time provided in Action A.1, the fuel must be l placed in a safe and analyzed condition in the spent fuel pool. -The Completion Time is reasonable based on the time required to move and unload an SSSC in an orderly manner and ;

without challenging the operating personnel. ;

SURVEILLANCE SJL 3.1.4.1 REQUIREMENTS SSSC seal integrity must be verified in accordance with 10 CFR 72.122(h)(4) and 10 CFR 72.128(a)(1). The method for verifying seal integrity varies with SSSC cask design-and is specified in Table 3-1 for each design. Normally, SSSC seal ;

integrity is verified using installed instrumentation that .j alarms at a central panel. If this system is not operating '!

on one or more SSSCs, monitoring of seal integrity at each !

affected SSSC may be performed. !

l Monitoring of the SSSC seal integrity is performed once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Frequency is based on maintaining cognizance ;

of facility conditions. I i

i REFERENCES None.

l l

l North Anna ISFSI B 3.1-12 Amendment No.

. SSSC Maximum Lifting Height B 3.1.5 B 3.1 SSSC INTEGRITY B 3.1.5 SSSC Maximum Lifting Height BASES BACKGROUND A loaded SSSC is transported between the power station protected area and the SSSC storage pad using a transporter.

The height to~ which the SSSC is lifted by the transporter is limited to ensure that the structural integrity of the SSSC is not compromised should the SSSC be accidently dropped.

APPLICABLE The structural analyses of the SSSCs demonstrate that a SAFETY ANALYSIS bottom-end drop of an SSSC from the Technical Specifications limit to an SSSC storage pad will not result in compromise of the SSSC integrity or physical damage to the contained fuel assemblies. The drop of an SSSC from a transporter at a greater height is not considered credible (Ref.1).

LC0 Limiting the SSSC lifting height during TRANSPORT OPERATIONS maintains the operating conditions of the SSSC within the design basis. The maximum lifting height is a function of the SSSC design and is specified in Table 3-1 for each design. i APPLICABILITY SSSC maximum lifting height applies during movement of the SSSC while suspended from the transporter. SSSC handling and drop events postulated to occur in the Fuel and Decontamination Buildings are addressed in the North Anna Power Station Updated Final Safety Analysis Report. SSSC drop events cannot occur-during STORAGE OPERATIONS as the SSSC is sitting on the ISFSI storage pad.

(continued)

North Anna ISFSI B 3.1-13 Amendment No.

I

. SSSC Maximum Lifting Height ,

B 3.1.5 l BASES (continued)

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SSSC.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SSSC not meeting the LCO.. Subsequent SSSCs that don't meet l the LCO are governed by subsequent Condition entry and I application of associated Required Actions. i A.1 If the SSSC lifting height is higher than the limit, immediate action must be taken to lower the SSSC to within I the limit. )

SURVEILLANCE SR 3.1.5.1 !

REQUIREMENTS l SSSC lifting height must be measured prior to TRANSPORT ;

OPERATIONS. The Frequency of I hour prior to initiation of l TRANSPORT OPERATIONS was chosen to verify the lifting height shortly before the SSSC is transported. i i

REFERENCES 1. SAR, Section 8.2.9.

North Anna ISFSI B 3.1-14 Amendment No.

L_

.. Dissolved Boron Concentration B 3.2.1

! B 3.2' SSSC CRITICALITY CONTROL' I I

B 3.2.1 Dissolved Boron Concentration ~ l BASES' 1

- BACKGROUND The SSSCs are designed to maintain the fuel subcritical l "i

under'all credible conditions with a K !

l Criticality control of an SSSC drained of ,, $water 0.95.is l maintained by neutron absorbers contained in the fuel l

. basket. While the SSSC is in the spent fuel pool or filled ,

with water, additional neutron absorber is r.2cessary to .I counteract neutron moderation by the water. As a result, the water must be borated to provide additional criticality control.

APPLICABLE The SSSCs are designed to maintain the stored fuel in.a j SAFETY ANALYSIS subcritical condition assuming a single active;or passive failure and an infinite number SSSCs stored together in close proximity (Ref. 1). The methods for criticality control vary by SSSC design, and some rely on borating the water used to fill the fuel cavity to counteract its neutron moderating effect. The effects on subcriticality from- ]

misloading a fuel assembly into an SSSC which is more. 1 reactive than the authorized assemblies 'has been analyzed :

(Ref.2). Maintaining the spent fuel pool boron )

concentration at or above the Technical Specification limit 1 l

prevents violation of the criticality design criterion. !

I

~ LCO When an SSSC is in the spent fuel pool, the water in the spent fuel pool must have a boron concentration 1 the limit in Table 3-1. The limit is a function of the SSSC design, and Table 3-1 contains the appropriate limit for each SSSC design. If water 1s added to the SSSC feel' cavity from a 'j source other than the spent fuel' pool, the boron !

concentration of that water must be t the limit in Table 3.-l. Placing a lower limit on the boron concentration !

of the water in .the SSSC fuel cavity ensures that the fuel i L

in the SSSC remains subcritical.

i (continued)

North Anna ISFSI' B 3.2-1 , Amendment No.

, Dissolved B:ron Concentration 3 B 3.2.1 i BASES (continued)

APPLICABILITY The boron concentration of the water in the SSSC fuel cavity must be within its limit whenever there is water in the fuel cavity. This occurs during LOADING OPERATIONS and UNLOADING OPERATIONS. During TRANSPORT OPERATIONS and STORAGE OPERATIONS, the SSSC fuel cavity is dry and fuel criticality control is provided by fixed neutron absorbers in the fuel cavity.

ACTIONS A.1 If the dissolved boron concentr. tion in the spent fuel pool or the SSSC fuel cavity is not within limit, loading of any additional fuel ' assemblies into the SSSC fuel cavity must be stopped. Without the required concentration of dissolved boron in the water, maintaining the subcriticality limit in all conditions cannot be guaranteed. The immediate Completion Time reflects the importance of prohibiting the introduction of any potential positive reactivity addition into the SSSC fuel cavity without the required boron concentration. UNLOADING OPERATIONS can proceed, as the spent fuel pool criticality analysis does not assume the <

presence of dissolved boron to achieve the required suLcriticality margin. In this case, moving fuel assemblies from the SSSC fuel cavity into the spent fuel pool racks is I an acceptable compensatory measure, j A.2 If the dissolved boron concentration in the spent fuel pool ,

or the SSSC fuel cavity cannot be brought within the limit, ,

all fuel assemblies must be removed from the SSSC. This I restores the fuel assemblies to an analyzed condition in the spent fuel pool. The Completion Time takes into consideration the time to change the boron concentration of a large spent fuel pool and the time to unload a loaded SSSC.

1 (continued)

North Anna ISFSI B 3.2-2 Amendment No. l

.. Dissolved Boron Concentratien B 3.2.1 BASES (continued)

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS This SR ensures that the boron concentration in the spent fuel pool and in water added to the SSSC fuel cavity is within the limits in Table 3-1 during LOADING OPERATIONS.

The boron concentration is determined periodically using chemical analysis.

The requirement to verify the boron concentration with 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to connencing LOADING OPERATIONS ensures that the water added to the SSSC fuel cavity is within the limit.

The Frequency of every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter is a reasonable .

amount of time to verify the boron concentration of l representative samples. The Frequency is based on operating experience that the boron concentration in the spent fuel ,

pool changes very slowly. i SR 3.2.1.2 This SR ensures that the boron concentration in the spent fuel pool and in water added to the SSSC fuel cavity is within the limits in Table 3-1 during UNLOADING OPERATIONS.

The boron concentration is determined periodically using chemical analysis. '

The requirement to verify the boron concentration with 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to commencing UNLOADING OPERATIONS ensures that ,

the water added to the SSSC fuel cavity is within the limit. '

The Frequency of every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter is a reasonable amount of time to verify the boron concentration of representative samples. The Frequency is based on operating experience that the boron concentration in the spent fuel pool changes very slowly.

REFERENCES 1. SAR, Section 3.3.4.

2. SAR, Section 8.2.6.

North Anna ISFSI B 3.2-3 Amendment No.

SSSC Average Surface Dose Rates B 3.3.1 B 3.3 SSSC RADIATION PROTECTION B 3.3.1- SSSC Average Surface Dose Rates BASES BACKGROUND The regulations governing the operation of an ISFSI set limits on the control of occupational radiation exposure and radiation doses to the general public (Ref. 1).

Occupational radiation exposure should be kept as low as reasonably achievable (ALARA) and within the limits of 10 CFR Part 20. Radiation doses to the public are limited for both normal and accident conditions. In addition, the sum of the SSSC average surface dose rates determines the ISFSI perimeter dose rates discussed in Specification 3.3.3, ISFSI Perimeter Radiation.

. APPLICABLE The SSSC average surface dose rates are not an assumption j SAFETY ANALYSIS in any accident analysis, but are used to. ensure compliance I with regulatory limits on occupational dose and dose to the I public.

I LC0 The limits on SSSC average surface dose rates are based on' the shielding analysis in the SAR (Ref.1). The limits were selected to minimize radiation exposure to the general public and maintain occupational dose ALARA to personnel working in the vicinity of the SSSCs. Compliance with the SSSC surface dose rate limits also ensures compliance with LCO 3.3.3, ISFSI Perimeter Radiation during STORAGE OPERATIONS.

i APPLICABILITY The SSSC average surface dose rates apply during LOADING OPERATIONS. These limits ensure that the SSSC average surface dose rates during TRANSPORT OPERATIONS, STORAGE OPERATIONS, and UNLOADING OPERATIONS are within the estimates contained in the SAR.

(continued) l North Anna ISFSI B 3.3-1 Amendment No.

i

L. SSSC Average Surface Dose Rates B 3.3.1 l BASES (continued) l l ACTIONS A Note has been added to the ACTIONS which states that, for i this LCO, separate Condition entry is allowed for each SSSC.

l This is acceptable since the Required ' Actions for each l Condition provide appropriate compensatory measures for each l SSSC not meeting the LCO. Subsequent SSSCs that don't meet

! the LCO are governed by subsequent Condition entry and application of associated Required Actions.

l A.1.1 l

If the SSSC average surface dose rates are not within limits, it could be an indication that a fuel assembly was )

inadvertently loaded into the SSSC that did not meet the Function and Operating Limits in Section 2.0.

Administrative verification of the SSSC fuel loading, by 1 means such as review of video recordings and records of the l

loaded fuel assembly serial numbers, can establish whether a )

misloaded fuel assembly is the cause of the out of limit condition. The Completion Time is based on the time l required to perform such a verification.

l A.1.2 If the SSSC average surface dose rates are not within l limits, and it is determined that the SSSC was loaded with l the correct fuel assemblies, an analysis may be performed to determine if the SSSC, once located at the ISFSI, would i result in the ISFSI offsite or occupational calculated doses exceeding the' regulatory limits in 10 CFR Part 20 or 10 CFR 72. If it is determined that the out of limit average surface dose rates do not result in the regulatory l limits being exceeded, TRANSPORT OPERATIONS may proceed. l A.2 l

If it is not verified that the ISFSI offsite radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72 l will be met with the SSSC average surface dose rates above L the LCO limit, all fuel assemblies must be removed from the

! SSSC. The Completion Time is reasonable based on the time L required to move and unload an SSSC in an orderly manner and ,

without challenging the operating personnel. !

l l

(continued)

North Anna ISFSI B 3.3-2 Amendment No.

SSSC Average Surface Dose Rates f B 3.3.1

!' BASES _(continued) l I' SURVEILLANCE SR 3.3.1.1 REQUIREMENTS This-SR ensures'that the SSSC average surface dose rates are within the LCO limits prior to transporting the SSSC to the ISFSI. The surface dose rates'are measured using hand-held radiation monitors following industry practices for detemining average surface dose rates. for large containers.

REFERENCES 1. 10 CFR Part 72.

l l

I I

1 i

North Anna ISFSI B 3.3-3 Amendment No.

l

i *

'. SSSC Surface Contaminatien B 3.3.2 B 3.3 SSSC RADIATION PROTECTION B 3.3.2 SSSC Surface Contamination BASES l

BACKGROUND An SSSC is immersed in the spent fuel pool in order to load

, the spent fuel assemblies. As a result, the surface of the l SSSC becomes contaminated with the radioactive material in the spent fuel pool water. This contamination is removed prior to moving the SSSC to the ISFSI in order to avoid i spreading the radioactive contamination to personnel or the ISFSI. This allows the ISFSI to be entered without controls to' prevent the spread of contamination and reduces personnel dose due to the spread of loose contamination or airborne contamination. This is consistent with ALARA practices.

APPLICABLE The radiation protection measures implemented at the ISFSI SAFETY ANALYSIS are based on the assumption that the exterior surfaces of the SSSCs have been decontaminated (Ref. 1). Failure to decontaminate the surfaces of the SSSCs could lead to higher than projected occupational doses.

l i LCO Removable surface contamination on the SSSC exterior i surfaces is limited to 1000 dpm/100 cm from beta and gamma sources and 20 dpm/100.cm from alpha sources. These limits are taken from the guidance provided in IE Circular 81-07 (Ref. 2) and are based on the minimum level of activity that can be routinely detected under a surface contamination control' program using direct survey methods. Only loose l contamination is controlled, as fixed contamination will not result from the SSSC loading process. Experience has shown ;

that these limits are low enough to prevent the spread of contamination to clean areas and are significantly less than the levels which would cause significant personnel skin l dose.

l l

I

(continued)

North Anna ISFSI B 3.3-4 Amendment No.

L l '

. SSSC Surface Contamination l B 3.3.2 BASES (continued)

APPLICABILITY Verification that the SSSC surface contamination is less than the LC0 limit is perfonned during LOADING OPERATIONS.

This occurs before TRANSPORT OPERATIONS and STORAGE OPERATIONS. Measurement of the SSSC surface contamination is unnecessary during UNLOADING OPERATIONS as surface contamination would have 'been measured prior to moving the subject SSSC to the ISFSI.

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SSSC.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SSSC not meeting the LCO. Subsequent SSSCs that don't meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

A.1 If the removable surface contamination of an SSSC that has been loaded with spent fuel is not within the LC0 limits, action must be initiated immediately to decontaminate the l SSSC and bring the removable surface contamination within ;

limits. The Completion Time of "Immediately" is appropriate l in order to minimize the potential for personnel contamination and given that the time needed to complete the l decontamination is unknown. I SURVEILLANCE SR 3.3.2.1 REQUIREMENTS This SR verifies that the removable surface contamination on the SSSC is less than the limits in the LCO. The Surveillance is performed using smear surveys to detect removable surface contamination. The Frequency requires performing the verification prior to initiating TRANSPORT OPERATIONS in order to confirm that the SSSC can be moved to the ISFSI without spreading loose contamination.

1 (continued)

)

North Anna ISFSI B 3.3-5 Amendment No.

. SSSC Surface Contamination B 3.3.2 BASES (continued)

REFERENCES - 1. SAR, Section 7.2.1.

2. IE Circular 81-08 Control of Radioactively Contaminated Material, May 15, 1981.

,. 4 l.

l l

\

I l

' l I

i l

l' North Anna ISFSI B 3.3-6 Amendment No.

t , :

. . ISFSI Perimeter Radiation B 3.3.3 8 3.3 SSSC RADIATION PROTECTION B 3.3.3 SSSC Perimeter Radiation BASES BACKGROUND The regulations governing the operation of an ISFSI set limits on radiation doses to the general public (Ref.1) for q both normal and accident conditions. This specification 4 provides conservative limits on the ISFSI's contribution to l the radiation doses at the ISFSI perimeter fence in order to i ensure that those regulatory limits are met. !

1 APPLICABLE The.ISFSI perimeter radiation levels are not an assumption SAFETY ANALYSIS in any accident analysis, but are used to ensure compliance '

l with regulatory limits on dose to the public during normal conditions.

LCO The limits on ISFSI perimeter radiation levels are based on i analyses described in the SAR (Ref.1). The limits were {

selected to maintain radiation doses to the general public

!_ within the limits provided in the regulations.

)

APPLICABILITY The ISFSI perimeter radiation limits apply during STORAGE OPERATIONS when SSSCs containing one or more fuel assemblies ,

are stored within the TSFSI perimeter.- Average surface dose I rate limits on individuel SSSCs are provided in R Specification 3.3.1, SSSt Average Surface Dose Rate, during I LOADING OPERATIONS and tht.:e limits ensure that occupational !

doses during TRANSPORT OPELTIONS and UNLOADING OPERATIONS i are within the estimates cont'ined in the SAR. !

(continued) i North Anna ISFSI B 3.3-7 Amendment No.

j

I l

l qs

ISFSI Perimeter Radiation B 3.3.3

!- BASES-(continued) l l' ACTIONS A.1 If the ISFSI perimeter radiation is not within limits, action must be initiated immediately to restore the perimeter radiation to within the LCO limits. Failure to meet the ISFSI perimeter limits could lead to exceeding the limits on dose to the general public. As a result, immediate action to correct the situation must be initiated.

SURVEILLANCE SR 3.3.3.I REQUIREMENTS This SR ensures that the ISFSI's contribution to the radiation doses (both neutron and gama) at the ISFSI perimeter fence are within limits. These doses are determined using thermoluminescent detectors (TLDs) located at the ISFSI perimeter. These TLDs are exchanged and read quarterly.

REFERENCES 1. SAR, Section 7.3.2.2.

I l

1 l North Anna ISFSI B 3.3-8 Amendment No.

l 1

ML20217N412

Text

Navigation menu

Search