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Proposed Tech Specs 3.6.1.1,3.6.1.2 & 3.6.1.3 Re Containment Airlocks
	ML20248H718
Person / Time
Site:	Sequoyah
Issue date:	10/05/1989
From:	; TENNESSEE VALLEY AUTHORITY
To:	;
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ML20248H716	List: ML20248H714; ML20248H718;
References
	NUDOCS 8910120031
	Download: ML20248H718 (11)
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ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-89-39)

LIST OF AFFECTED PAGES Unit i 1-2 3/4 6-1 3/4 6-4 Unit 2 1-2 3/4 6-1 3/4 6-4 I l

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CHANNEL FUNCTIONAL TEST-

.1. 6 A CHANNEL FUNCTIONAL TEST shall be:

a. Analog channels - the injection of a simulated signal into the-l channel as close to the sensor as practicable to verify OPERABILITY-

-including alarm and/or trip functions.

b. Bistable channels - the injection of a simulated signal into the sercor to verify OPERABILITY including alarm and/or trip functions.

CONTAINMENT INTEGRITY

1. 7 CONTAINMENT INTEGRITY shall exist when: lR75-

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

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

2) Closed by manual valves, blind flanges,-or deactivated automatic valves secured in their closed positions, except as provided in Table 3.6-2 of Specification 3.6.3.

b. All equipment hatches are closed and sealed.

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c. Each air lock is O^:?"LE ;r=r,t te Specification 3.6.1.3,

d. The containment leakage rates are 'within the limits of Specification 3.6.1.2, and

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

welds, bellows, or 0-rings) is OPERABLE.

CONTROLLED LEAKAGE _

1.8 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor coolant pump seals. lR75 CORE ALTERATION 1.9 CORE ALTERATION shall be the movement or manipulation of any component R75 within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.

SEQUOYAH - UNIT 1 1-2 Amendment No. 12X 71 May 18, 1988

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3/4.6 CONTAINMENT SYSTEMS C i 3/4.6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY UMITINGCONDITIONFOROPERATION l

3.6.1.1 Primary CONTAINMENT INTEGRITY 'shall be maintained.

APPLICABILITY: MODES 1, 2, 3 and 4.

l ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that all penetrations

not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves i

secured in their positions, except as provided in Table 3.6-2 of Specification 3.6.3.

b. By verifying that each containment air lock is -OPE"LE gr.4h ccop dr4de wd ((te Specification 3.6.1.3.

VettoLYes%ttbb k U c. After each closing of each penetration subject to Type B testing, except the containment air locks, if opened following a Type A or B test, by leak rate testing the seal with gas at P 3, 12 psig, and verifying that when the measured leakage rate for these seals is added to the leakage rates determined pursuant to Specification 4.6.1.2.d for all other Type B and C penetrations, the combined leakage rate is less than or equal to 0.60 L,.

Except valves, blind flanges, and deactivated automatic valves which are located inside the annulus or containment and are locked, sealed or otherwise

' secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed

, more often than once per 92 days.

SEQUDYAH - UNIT 2 3/4 6-1 September 15, 1981 1

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CONTAINMENT SYSTEMS l

SURVEILLANCE REQ'UIREMENTS (Continued) (

3. Valves pressurized with fluid from a seal system.

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e. The combined bypass leakage rate to the auxiliary building shall be determined to be less than or equal to 0.25 La by applicable Type B R104l and C tests at least once per 24 months except for penetrations which are not individually. testable; penetrations not individually testable shall be determined to have no detectable leakage when tested with soap bubbles while the containment is pressurized to Pa , 12 psig, during each Type A test.

ec. Wet eaA ce%=edj

f. 1r locks ch ll b: tested =d d==:trated OPERACLE per Surveillar;;e Require...ir.t 4.G.1 h h in co+ph'ane< with & Mpbuh / Spec & cab j ' *l . 6. l.3.

g. Leakage from isolation valves that are sealed with fluid from a seal system may be excluded, subject to the provisions of Appendix J,Section III.C.3, when determining the combined leakage rate provided the seal system and valves are pressurized to at least 1.10 P a ,13.2 psig, and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 488, 49A and 498) for at

{}J R90 least 30 days.

h. Type B tests for penetrations employing a continuous leakage monitoring system shall be conducted at aP , 12 psig, at intervals no greater than once per 3 years.

i. All test leakage rates shall be calculated using observed data

' converted to absolute values. Error analyses shall be performed to select a balanced integrated leakage measurement system.

j. The provisions of Specification 4.0.2 are not applicable.

SEQUOYAH - UNIT 2 3/4 6-4 Amendment No. 63, 90 , 104 May 5, 1989

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DEFINITIONS.

9 CHANNEL FUNCTIONAL TEST '

1.6~ A CHANNEL FUNCTIONAL TEST shall be: lR63

a. Analog channels - the injection'of a simulated signal into the channel as.close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.

b. Bistable channels - the injection of.a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.

CONTAINMENT INTEGRITY 1.7 CONTAINMENT INTEGRITY shall exist when: lR63

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

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

2) Closed by manual valves, blind flanges, or deactivated auto-matic valves secured in their closed positions, except as provided in Table 3.6-2 of Specification 3.6.3.

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b. All equipment hatches are close and sealed,

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c. Each air lock is OPEnfSLE-pur::=t tp.kerMaks Specification 9 3.6.1.3,

d. The containment leakage rates are within the limits of Specification 3.6.1.2, and

e. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.

CONTROLLED LEAKAGE 1.8 CONTROLLED LEAKAGE shall be that seal water flow supplied to the reactor lR63 coolant pump seals.

CORE ALTERATION 1.9 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in lR63 1 i

the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position. {

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SEQUOYAH - UNIT 2 1-2 ~

Amendment No 63 May 18, 1988 l

1 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT i

j CONTAINMENT INTEGRITY i;

-LIMITING CONDITION FOR OPERATION -

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I 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

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a. At least once per 31 days by verifying that all penetrations

not j capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are R16 closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-2 of Specification 3.6.3.

in to&iar ce wifb NB e

b. By verifying that each containment air lock isGERACLE per reguire,rewts of Specification 3.6.1.3.

c. After each closing of each penetration subject to Type B testing, except the containment air locks, if opened following a Type A or l B test, by leak rate testing the seal with gas at P , 12 psig, and R16 I verifying that when the measured leakage rate for tflese seals is I added to the leakage rates determined pursuant to Specification 4.6.1.2.d for all other Type B and C penetrations, the combined leakage rate is less than or equal to 0.60 L,.

^Except valves, blind flanges, and deactivated automatic valves which are located inside the annulus or containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

s MAN 261982 12 SEQUOYAH - UNIT 1 3/4 6-1 Amendment No.

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CONTAINMENT: SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)-

e. The' combined _ bypass leakage rate to the auxiliary building shall be R75

' determined to be .less than or equal to 0.25 La by applicable Type'B and C tests at least once per 24 months except for penetrations;which are not individually testable; penetrations not individually testable-shall be. determined to have no detectable leakage when tested with soap bubbles during each Typewhile the containment is pressurized to Pa (12 psig)

A test.

svenly %g Acd ends in%t 3 Air locks sh;P be tested ar.d de crstrated ^"C"A"LE per Suruaillenre-Requi" aman + aA SpedkN 3.le.l.3. 1. 3. Is ivi coghance, MS tke, rqWremed 08

g. Leakage from isolation valves that are. sealed with fluid from a seal system may be excluded,. subject to the provisions of Appendix J,Section III.C.3, when determining the.. combined leakage rate provided the seal system and. valves are pressurized to at least-1.10 Pa (13.2 psig) and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 488, 49A and 49B) for at R105 least 30 days.

l .. h. Type B tests for penetrations employing a continuous leakage t

l monitoring system shall be. conducted at Pa (12 psig) at intervals no.

greater than once per 3 years.

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All: test leakage rates shall be calculated using observed data converted to absolute. values. Error analyses shall be. performed to select a balanced integrated leakage measurement system.

j. The provisions of Specification 4.0.2' are not applicable.

R106 SEQUOYAH - UNIT 1 3/4 6-4 Amendment No.12, 7L 101,102 March 2, 1989

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! j ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-89-39)

DESCRIPTION AND JUSTIFICATION FOR CLARIFICATION OF AIR LOCK REQUIREMENTS CONTAINED IN SPECIFICATION 3.6.1.1 AND THE DEFINITION OF CONTAINMENT INTEGRITY i.

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l ENCLOSURE 2 9

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~ Description of Change

' Tennessee Valley Authority proposes to modify the Sequoyah Nuclear' Plant (SQN) Units 1 and 2 technical specifications (TSs) to revise the definition;of containment integrity and' Surveillance Requirements (SRs) 4.6.1'.1.b'and 4.6.1.2.f. :The proposed changes modify the requirements for containment air locks to be consistent with Revisien-5 of' NRC's NUREG-0452, " Standard Technical Specifications for Westinghouse Pressurized Water Reactors" (H STS).

Reason for Change The definition of' containment. integrity and SRs 4.6.1.1.b and 4.6.1.2.f.

used in;the SQN TSs'contain the' requirement that the containment air locks

P 'be' operable. This wording is consistent with Revision 4 of the E STS.

The wording used in-Revision 5 of the E STS for- these same TSs requires compliance with TS 3.6.1.3 for the containment air locks..

The specific wording of SQN.TS 3.6.1.1 may lead to an interpretation that precludes the use of the action provisions in TS 3.6.1.3 when an air lock is inoperable but still within.the allowed leakage limits of'TS 3.6.1.2.

On'the other hand,.the specific wording in Revision 5 of the E STS allows the use of the action provisions in TS 3.6.1.3. The proposed change ,

modifies the SQN TS to conform with Revision 5 of the E STS and eliminates

the potential for misinterpretation.

Justification for Change containment air lock operability consists of two separate aspects:

Physical integrity of the doors is addressed by TS 3.6.1.3.a. and overall air lock leakage is addressed by TS 3.6.1.3.b. The overall air lock leakage must also satisfy the conditions of TSs 3.6.1.2.b and 3.6.1.2.c.

These same elements of containment air lock operability are addressed by

-reference in TS 3.6.1.1 and the definition of containment integrity.

Action Statement a in TS 3.6.1.3 addresses the case where one air lock door is inoperable. This action statement addresses the failure to meet the requirement of TS 3.6.1.3.a. Action Statement b addresses the case where'the air lock is inoperable for reasons other than an inoperable door (e.g., leakage in excess of the requirement in TS 3.6.1.3.b).

Air lock leakage in excess of the requirements of TS 3.6.1.3.b renders the air lock inoperable. The air lock leakage may also present a containment integrity problem if the air lock leakage exceeds the limits of either TSs 3.6.1. 2.b or 3. 6.1. 2.c. The containment integrity requirement is imposed through TS 3.6.1.1 and Item d in the definition of containment integrity.

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The 24-hour-allowable, out-of-service time in Action b is both reasonable and prudent for the cases where air lock leakage renders the air lock inoperable but does not present a containment integrity problem. The 24-hour period provides time to repair the air lock before imposing a plant transient and plant shutdown.

The 1-hour-allowable, out-of-service time in the action statement for TS 3.6.1.1 is appropriate for the cases where air lock leakage represents a containment integrity problem.

The proposed changes to the containment integrity definition, SR 4.6.1.1.b and SR 4.6.1.2.f. clarify the requirements for air lock inoperability for the cases where overall air lock leakage does not present a containment integrity problem. The proposed changes do not affect the overall containment leakage requirements imposed through TSs 3.6.1.1 and 3.6.1.2.

The proposed changes to the definition of containment integrity and SR 4.6.1.1.b are consistent with Revision 5 of the E STS. An additional change is proposed to SR 4.6.1.2.f to utilize consistent language when the air lock requirements from TS 3.6.1.3 are referenced.

Environmental Impact Evaluation The proposed change request does not involve an unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the Staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board.

2. Result in significant change in effluents or power levels.

3. Result in matters not previously reviewed in the licensing basis for SQN that may have a significant environmental impact.

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o ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2

p DOCKET NOS. 50-327 AND 50-328 e,

(TVA-SQN-TS-89-39)

DETERMINATION OF NO SIGNIFICANT HAZARDS' CONSIDERATIONS

ENCLOSURE 3 i Significant Hazards Evaluation TVA has evaluated the proposed TS change and has determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of SQN in accordance with the proposed amendment will not:

l (1) Involve a significant increase in the probability or consequences of j an accident previously evaluated. {

As described in Section 6.2 of the Final Safety Analysis Report (FSAR), the containment structure is designed to ensure that an acceptable upper limit of leakage of radioactive material is not exceeded under design basis accident conditions. The containment air locks, which provide personnel access to both upper and lower containment, were designed and constructed and are tested to ensure that the allowable leakage limits for containment are maintained.

The proposed changes to the definition of containment integrity and SRs 4.6.1.1.b and 4.6.1.2.f are made to clarify the use of the action provisions of TS.3.6.1.3. The actual acceptance criteria for primary containment and air lock leakage rates remain unchanged. As such, the proposed change is administrative in nature and serves to i eliminate the potential for misinterpretation of the TS requirements. The proposed change does not increase the probability of a previously evaluated accident because the primary containment and air lock leakage rates are not associated with the initiation of any design basis accident. Because the acceptable limits on the primary containment and air lock leakage rates remain unchanged, the consequences of a previously evaluated accident are not increased.

(2) Create the possibility of a new or different kind of accident from any previously analyzed.

As described above, the proposed changes to the definition of containment integrity and SRs 4.6.1.1.b and 4.6.1.2.f are made to clearly allow the use of the action provisions of TS 3.6.1.3. The acceptance criteria for primary containment and air lock leakage rates remain unchanged. Thus, no radiological consequence analysis assumptions are changed. The proposed changes are administrative in nature and serve to eliminate the potential for misinterpretation of the TS requirements. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any previously analyzed.

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J (3) Involve a significant reduction in a margin of safety.

The proposed changes to the definition of containment integrity and SRs 4.6.1.1.b and 4.6.1.2.f are made to clarify the use of the action provisions of TS 3.6.1.3. The proposed changes are administrative in nature and serve to eliminate the potential for misinterpretation of the TS requirements. The actual acceptance criteria for primary containment and air lock leakage rates are not changed. As such, the i assumptions and, consequently, the results of SQN's radiological consequence analyses remain unchanged, and the bases of TSs 3.6.1.1 and 3.6.1.3 are not altered. Therefore, the proposed changes do not reduce the margin of safety.

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ML20248H718

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